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to Texas and petitioner’s address be the address of the Dallas
apartment, effective January 1, 1992. The board also resolved:
The rental expense for the Corporation offices in
Dallas, Texas shall not exceed $1,500.00 per month.
The actual rental shall be the association maintenance
fees charged by the Claridge Association to the
residents of 3510 Turtle Creek Blvd. All additional
charges including the acquisition of the unit, property
taxes, insurance, and telephone expense shall be borne
personally by Norman E. Duquette and shall not be
charged to the Corporation.
Norman prepared a document headed “COMPUTATION OF FAIR RENTAL[,]
OFFICE AT 3510 TURTLE CREEK BLVD.[,] DALLAS, TEXAS” (the
computation document). Among the entries on the computation
document is the following:
1. Square Footage Proration
a. Business Use 625 square feet
b. Total Square Footage 2,500 square feet
c. Percentage Business 25 percent
The computation document also has entries entitled “Annual
Expenses”, “Prorated Expenses”, “Unique Business Expenses”, and
“Total Business Expenses”. The amount shown as “Total Business
Expenses” is $12,919.29. The computation document states: “The
corporation will pay the association fees of $11,477.16 as fair
rental for the office in home. This is less than the $12,919.29
calculated * * * [as “Total Business Expenses”].”
The parties have stipulated that the $7,540 deducted by
petitioner as rent for space in the Dallas apartment (the Dallas
apartment amount) represents condominium fees with respect to the
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