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stored her business records and professional reading materials
there. She did not meet with any of her patients at the
apartment.
Petitioner’s 1996 Federal income tax return was timely
filed. Various deductions claimed on her return were disallowed
by respondent in the notice of deficiency, but the parties are
now in agreement with respect to those adjustments.
Discussion
Petitioner now claims that she is entitled to deductions for
one-quarter of the rent and utilities paid for the apartment (the
home office expenses) because she used the apartment for business
purposes in her private practice. She also now claims that she
is entitled to a deduction for the interest paid during 1996
that relates to the portion of her student loan attributable to
obtaining her Ph.D.1 because that interest was paid in connection
with educational expenses that were deductible as trade or
business expenses.
1. Deduction for Home Office Expenses
During 1996, petitioner spoke over the telephone with
patients and professional colleagues from her apartment,
she scheduled appointments from her apartment, she maintained
and stored business records there, and she read professional
1 Petitioner estimates that 63 percent of the student loans
were made to obtain her Ph.D.
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