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to any deduction claimed. Rule 142(a); INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v.
Helvering, 292 U.S. 435, 440 (1934). This includes the burden of
substantiation. Hradesky v. Commissioner, 65 T.C. 87, 90 (1975),
affd. per curiam 540 F.2d 821 (5th Cir. 1976).
Section 162(a) generally allows a deduction for all ordinary
and necessary expenses paid or incurred during the taxable year
in carrying on any trade or business. The regulations
promulgated under section 162 clarify that only those ordinary
and necessary business expenses "directly connected with or
pertaining to the taxpayer's trade or business" may be deducted.
Sec. 1.162-1(a), Income Tax Regs. In addition, under section
262(a), no portion of the expenditures attributable to personal,
living, or family expenses may be deducted.
We now apply these principles to the various expenses
petitioners claimed on their Schedule C for 1992.
A. Home Office Deduction
Section 280A narrows the general deductibility rule of
section 162 when deductions are claimed for the expenses of a
home office. Sec. 280A(a).
Section 280A(a) denies deductions with respect to the use of
a dwelling unit used by the taxpayer as a residence during the
taxable year. Section 280A(c), however, permits the deduction of
expenses allocable to a portion of the dwelling unit that is used
exclusively and regularly as "the principal place of business"
for any trade or business of the taxpayer. Sec. 280A(c)(1)(A).
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