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the provisions of section 280A(c)(5) and the fact that her
Schedule C for D.C. Enterprises reflected a loss of $3,311.
In the case involving 1993 and 1994, respondent had not
contested the substantiation of the claimed qualified expenses
which petitioners used in computing their home office deductions.
In the instant case, respondent has agreed to accept the Court’s
findings for 1993 and 1994; however, respondent contends that
petitioners have not substantiated any of the items making up the
qualified expenses for purposes of the home office deduction.
Petitioners have claimed surprise and were not prepared at trial
to substantiate these items. Accordingly, the Court kept the
record open for purposes of receiving in evidence copies of
petitioners’ substantiating documents with respect to insurance
and utilities. Interest and taxes were already documented and
unchallenged on the 1995 Form 1040 Schedule A.
Subsequently, petitioners filed a motion to supplement the
record offering: (1) A revised Form 8829, Expenses for Business
Use of Your Home (marked for identification as Exhibit 8-P); (2)
two premium statements from Fireman’s Fund Insurance Co. (marked
for identification as Exhibit 9-P); (3) a bill showing payments
for water service, power and sewer for March 1, 1994 through 1996
(marked for identification as Exhibit 10–P); (4) records of fire
insurance from Cal-Vet Fire Insurance and TIG Insurance (marked
for identification as Exhibit 11-P); (5) 11 pages of canceled
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Last modified: May 25, 2011