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Dole v. Commissioner, 43 T.C. 697, 706 (1965), affd. per curiam
351 F.2d 308 (1st Cir. 1965). The employer need not explicitly
require the employee to use the property. Similarly, a mere
statement by the employer that the use of the property is a
condition of employment is not sufficient. See sec. 1.280F-
6T(a)(2)(ii), Temporary Income Tax Regs., supra. Petitioners
have not demonstrated that the acquisition of the computer
equipment was for the convenience of Mr. Coffman’s employer;
therefore, they are not entitled to a section 179 deduction for
those assets.
Home Office
Petitioners did not claim a deduction for home office on
their 1995 return, which failure petitioners contend was
inadvertent. Petitioners now claim that they are entitled to
claim home office deductions totaling $6,902 pertaining to Mrs.
Coffman’s Schedule C business and Mr. Coffman’s employment.
Petitioners’ 1993 and 1994 Federal income taxes were before
this Court in docket No. 22154-97S, for which Summary Opinion
1999-134 was filed on August 5, 1999. In that opinion, we held
that Mr. Coffman was entitled to a deduction for home office
based upon 9 percent of the qualified expenses as an itemized
deduction on Schedule A. We held further that Mrs. Coffman was
not entitled to a deduction for a home office expense because of
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