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Kropp v. Commissioner, T.C. Memo. 2000-148. Deerwood is only
about 10 miles closer to downtown Jacksonville than is Ponte
Vedra Beach, which is within the metropolitan Jacksonville
area, and petitioner did not convincingly establish that she
patronized the printing company on such a frequent basis or
that her time was so valuable as to justify paying considerable
rent on a condominium only marginally closer to downtown than
her personal residence.
More compelling is the fact that Deerwood is a gated,
residential golf course community and not a business office
park. Petitioner’s adult daughter, adult son (a practicing
attorney), and elderly mother all lived in petitioner’s
condominium at Deerwood at various times during the years in
issue. Under these circumstances, we think it was incumbent on
petitioner to demonstrate that some portion of the Deerwood
condominium was exclusively used on a regular basis as either
her principal place of business or as a place of business used
by clients in meeting or dealing with her in the normal course
of her trade or business. See sec. 280A(c)(1)(A) and (B);
Hefti v. Commissioner, T.C. Memo. 1993-128. However,
petitioner failed to do so.
Insofar as the residence in Ponte Vedra Beach is
concerned, petitioner introduced no persuasive evidence
whatsoever to support a finding that some portion of that
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