Michael T. Chappell - Page 18




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          (1980); sec. 1.162-7(a), Income Tax Regs.  Petitioner testified             
          that the payments to his children were based on their needs,                
          rather than the services they provided.  Petitioner wrote a check           
          to his wife for $3,300, dated February 6, 1994, and he testified            
          that it was payment to Nicole for running the one-room                      
          schoolhouse and tutoring students there.  He later testified that           
          the $3,300 payment was for Nicole’s braces.  Petitioner did not             
          describe what services Brooke and Tye performed for the tax                 
          preparation activity.  Petitioner has not shown that the                    
          purported wages he paid his children were for services actually             
          rendered or were reasonable in amount.                                      
               4.   Home Office Deduction                                             
               Section 280A(c)(1)(A)5 allows a deduction for home office              

               5  Sec. 280A provides, in pertinent part:                              
               SEC. 280A. DISALLOWANCE OF CERTAIN EXPENSES IN                         
               CONNECTION WITH BUSINESS USE OF HOME, RENTAL OF                        
               VACATION HOMES, ETC.                                                   
                    (a) General Rule.--Except as otherwise provided                   
               in this section, in the case of a taxpayer who is an                   
               individual or an S corporation, no deduction otherwise                 
               allowable under this chapter shall be allowed with                     
               respect to the use of a dwelling unit which is used by                 
               the taxpayer during the taxable year as a residence.                   
                              *   *   *   *   *   *   *                               
                    (c) Exceptions for Certain Business or Rental Use;                
               Limitation on Deductions for Such Use.--                               
                         (1) Certain business use.--Subsection (a)                    
                    shall not apply to any item to the extent such                    
                                                             (continued...)           





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