Michael T. Chappell - Page 20




                                       - 20 -                                         
          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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