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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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