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1.262(f)(2)(ii)” for the proposition that food and beverages
furnished on the taxpayer’s business premises are deductible and
not subject to the limitation on deductions. Apparently,
petitioner was referring to section 1.274-2(f)(2)(ii), Income Tax
Regs. However, this regulation does not assist petitioner’s
position as she failed to substantiate the deductions.
It is clear from the evidence submitted and the testimony
provided during trial that petitioner failed to substantiate in
any coherent manner expenditures she considered as office
expenses. On the basis of the record, we hold that petitioner is
not entitled to deduct office expenses in excess of respondent’s
allowed office expenses for the years in issue.
6. Rent - Other Expenses
Petitioner deducted rent expenses of $1,620, $4,375, and
$6,900 in 1991, 1992, and 1993, respectively. Respondent allowed
$1,700, $1,200, and $1,200, respectively. Petitioner contends
that the disallowed rental expenses associated with storage space
at her mother’s home and the Cass St. address are deductible.
Section 280A generally prohibits deductions of otherwise
allowable expenses with respect to the use of an individual
taxpayer’s home. This prohibition, however, does not apply to
space allocable within a “dwelling unit which is used on a
regular basis as a storage unit for the inventory or product
samples of the taxpayer held for use in the taxpayer’s trade or
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