Danielle L. Clark-Hernandez - Page 20




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          residences.  The exception clearly applies in situations where              
          the dwelling unit is the sole fixed location of the trade or                
          business.  Because petitioner had an office, her fixed place of             
          business, other than her residences, section 280A(c)(2) does not            
          apply.  See Garvey v. Commissioner, T.C. Memo. 1982-176.                    
          Moreover, petitioner’s equipment and supplies for her cleaning              
          business do not constitute inventory, as required under the                 
          statute.  See Banatwala v. Commissioner, T.C. Memo. 1992-483.               
               Accordingly, petitioner failed to establish that she is                
          entitled to deduct additional rents in excess of the amounts                
          respondent allowed.  Respondent is sustained on this issue.                 
               7.  Utilities                                                          
               Petitioner claimed utility expense deductions of $3,341,               
          $2,864, and $3,724 in 1991, 1992, and 1993, respectively.                   
          Respondent allowed $1,553, $1,564, and $1,220, respectively.  At            
          trial, petitioner agreed to 90 percent of respondent’s                      
          adjustments.  Petitioner admits that personal utility expenses              
          were incorrectly deducted in 1991, 1992, and 1993.  However, she            
          continues to contend that she is entitled to 10 percent of the              
          disallowed utility expense deductions.  It was also determined              
          that in 1991, yellow page advertisements charged to petitioner’s            
          telephone bills, were already included in petitioner’s claimed              
          utility expenses for that year, and no additional amount was                







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