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Section 280A(c)(1) provides an exception to this general rule for
any item allocable to a portion of the dwelling unit which is
exclusively used by the taxpayer on a regular basis as the
principal place of business for a trade or business of the
taxpayer. A taxpayer "exclusively" uses a portion of his
dwelling in a trade or business if and only if the portion in
question is not at any time during the taxable year used for
nonbusiness purposes. See Hefti v. Commissioner, T.C. Memo.
1993-128.
During the years at issue, petitioner resided in a one-
bedroom one-bathroom13 condominium containing 850 square feet of
living space. Petitioner designated 500 square feet of her
condominium as having been used for business purposes. The space
so designated includes her entire living room and dining room,
her entire bathroom, and the portion of the kitchen containing
the sink. While petitioner contends that she used this portion
of her condominium for business purposes, she does not contend
that such business use was exclusive. In any event, we would
find any claim of exclusive business use implausible.
Accordingly, we sustain respondent’s disallowance of the
deductions claimed by petitioner for business use of her home.
13 Petitioner testified that she added a second bathroom in
the closet of her bedroom. Petitioner, however, did not
introduce evidence of any such remodeling.
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