Robert Walter Allison - Page 9




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               3.  General                                                            
               Petitioner claimed a deduction for general expenses of                 
          $1,949.  Respondent disallowed $1,266 of this general expense.              
               As with other items of expense deductions, petitioner’s                
          testimony provided little guidance as to what was claimed under             
          the “general” category.  Although petitioner’s summary of his               
          credit card spending for 1995 is helpful to substantiate amounts            
          paid during that year, it provides no other helpful information.            
          Petitioner is required to provide a business purpose for expenses           
          claimed under section 162.  Without a clear indication of what              
          amounts constitute “general” expenses, we cannot allow a                    
          deduction in excess of respondent’s previously allowed amount.              
               Respondent is sustained on this issue.                                 
               4.  Business Use of Home                                               
               Section 280A generally prohibits deduction of otherwise                
          allowable expenses with respect to the use of an individual                 
          taxpayer’s home.  This prohibition, however, does not apply to              
          any item that is allocable to a portion of the home that is                 
          exclusively used on a regular basis as the principal place of               
          business for the taxpayer’s trade or business or to space that is           
          used on a regular basis for storage of the taxpayer’s inventory             
          held for use in the taxpayer’s trade or business of selling                 
          products at retail or wholesale.  Sec. 280A(c)(1) and (2).                  
               Petitioner claimed a Schedule C business use of home expense           






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