- 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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