Don D. Coffman and Debra Coffman - Page 8




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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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