Evelyn J. Glenn - Page 17




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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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