- 9 - item. Sanford v. Commissioner, 50 T.C. 823, 827 (1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969). The record does not contain any documentary evidence to support petitioner’s claimed car and truck expenses. Petitioner failed to maintain adequate records such as a diary, log book, or trip sheets to show the distances he purportedly traveled in furtherance of his locksmith business. Therefore, in view of the strict substantiation rules of section 274(d), we hold that petitioners are not entitled to deduct car and truck expenses for 1995. 3. Claimed Home Office Expenses Section 280A limits the situations in which a deduction of expenses related to a home office are allowable. There is an exception if a portion of the dwelling unit is used exclusively on a regular basis as the principal place of business for any trade or business of the taxpayer or as a place of business which is used by patients, clients, or customers in meeting or dealing with the taxpayer in the normal course of his trade or business. Sec. 280A(c)(1)(A),(B). Incidental or occasional meetings with customers are not enough to qualify the home office for this exception. Crawford v. Commissioner, T.C. Memo. 1993-192. In Commissioner v. Soliman, 506 U.S. 168 (1993), the Supreme Court held that when a taxpayer carries on business in more than one location the principal place of a taxpayer’s business is the most important or significant place of business. This turns onPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011