John A. and Margaret R. Gosling - Page 2

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               Respondent determined deficiencies in petitioners' Federal              
          income taxes for the taxable years 1993 and 1994 in the amounts              
          of $3,942 and $2,725, respectively.                                          
               After concessions by petitioners,2 the issue for decision is            
          whether petitioners are entitled to certain deductions.  Our                 
          disposition of this issue will depend upon whether petitioner                
          husband's home office constitutes his principal place of                     
          business.  We hold that petitioner husband's home office was his             
          principal place of business and that petitioners are therefore               
          entitled to the deductions at issue herein.                                  
                                   FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and are so found.               
          Petitioners resided in Savannah, Georgia, at the time that their             
          petition was filed with the Court.                                           

          issue, and all Rule references are to the Tax Court Rules of                 
          Practice and Procedure.                                                      
          2  Petitioners concede that they are not entitled to                         
          deductions for the following expenses:                                       
               Expense claimed           1993            1994                          
               Advertising              $100            $108                           
               Office                   485             --                             
               Travel                   6,475           6,960                          
               Other expenses           271             335                            
               Insurance                1,897           705                            

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