- 19 - 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 wasPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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