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this office contains a television. He testified that his
employees also used the kitchen and bathroom.
Petitioner did not establish that he used any portion of the
Lower Wetumpka Road house exclusively as the principal place of
business for his tax return business or as a place to meet with
clients. He used the bathroom and kitchen for personal purposes.
The television was in the second office. We do not find that
petitioner used these rooms exclusively for the tax preparation
activity because the rooms were used for non-business purposes by
the quilting group and the lobbying activity.
Petitioner contends that he is entitled to a home office
deduction for rent he paid to his estranged wife to use an office
at the Creek Drive house. He testified that he used the
following rooms in the Creek Drive house: A room for the one-room
schoolhouse, the kitchen, bathroom (for clients), and the back of
the house for a “rebreeding” program, not otherwise described in
the record.
Petitioner did not establish that he used any part of the
Creek Drive house as the principal place of business of a trade
or business. As discussed at paragraph D-1 above, he did not
show that the activity conducted in the one-room schoolhouse was
a trade or business. He did not use the kitchen and bathroom
exclusively for business, and he testified that his children did
their schoolwork in the room he called the one-room schoolhouse.
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