Evelyn J. Glenn - Page 16




                                        - 15 -                                        
           sec. 280A(c)(1).                                                           
                On her Schedules C for 1995 and 1996, petitioner claimed              
           deductions for “office expense” in the amounts of $2,647 and               
           $4,934, respectively, for “utilities” in the amounts of $2,690             
           and $1,712, respectively, and for “rent (other business                    
           property)” in the amounts of $7,200 and $4,800, respectively.              
           In the notice of deficiency, respondent disallowed the                     
           deductions claimed for “rent (other business property)”, but,              
           inexplicably, did not adjust the other deductions.                         
                The deductions claimed by petitioner for “rent (other                 
           business property)” represent deductions for an office in the              
           home.4  Notably, petitioner made no entry on line 30 of either             
           her 1995 or 1996 Schedule C for “Expenses for business use of              
           your home”, nor did she attach Form 8829, Expenses for Business            
           Use of Your Home, to either of her returns for those years.                
                At trial, petitioner testified that she rented the                    
           Deerwood condominium in order to be closer to downtown                     
           Jacksonville, where the printing company she patronized was                
           located.  However, we are unable to accept petitioner’s                    
           testimony at face value.  See Tokarski v. Commissioner, 87 T.C.            
           74, 77 (1986); Diaz v. Commissioner, 58 T.C. 560, 564 (1972);              



               4  As we understand petitioner’s testimony, the deduction in           
          1995 represents 50 percent of the rent paid for the Deerwood                
          condominium, whereas the deduction in 1996 relates to                       
          petitioner’s residence in Ponte Vedra Beach.                                





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