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condominium at 403 South Timber Drive in Nashville. Petitioner
began renting this condominium during the latter part of 1993.
Petitioner contends he used this condominium as an office during
the years at issue, even though he was in Nashville only 30 days,
37 days, and 44 days, respectively, for the years 1994, 1995, and
1996. Petitioner contends he maintained this office as a point
of contact in Nashville for potential clients. The condominium
was located in a residential area of Nashville. Petitioner
claims that he set up the downstairs portion of the condominium
as an office and kept an air mattress upstairs where he slept
when he stayed overnight in Nashville. There was a telephone and
answering machine but no fax machine or copy machine in the
condominium. Petitioner contended that no one lived in the
condominium when he was not in Nashville.
Petitioner testified that a woman named Debra Push (Ms.
Push), who petitioner identified as a songwriter, would
occasionally check the mail and answering machine for petitioner
when he was not in Nashville. Ms. Push was not compensated
monetarily for this service. The Court notes, however, that
petitioner incurred additional lodging expenses in Nashville
during the years at issue at Embassy Suites, Crowne Plaza,
Wyndham Garden Hotels, and similar establishments.9 Petitioner
testified that the reason for incurring these additional lodging
9 Sometimes these expenses were $100 or more per night.
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