Erin Mullin - Page 6




                                        - 6 -                                         
          purposes.  See Cook v. Commissioner, T.C. Memo. 1997-378.  The              
          area of the apartment used for business purposes was also the               
          main passageway through the apartment.  Furthermore, we have                
          serious doubts whether petitioner’s apartment qualifies as the              
          principal place of her private practice.  See Commissioner v.               
          Soliman, 506 U.S. 168 (1993); Strohmaier v. Commissioner, 113               
          T.C. 106, 112-113 (1999).  Nor did petitioner use the apartment             
          to meet with her private-practice patients.  Consequently,                  
          petitioner is not entitled to a deduction for the home office               
          expenses.                                                                   
          2. Deduction for Interest on Student Loans                                  
               During 1996, petitioner paid interest on student loans made            
          in connection with pursuing and obtaining her undergraduate and             
          graduate degrees.  She now claims that she is entitled to a                 
          deduction for a portion of that interest.                                   
               In general, there is “allowed as a deduction all interest              
          paid or accrued within the taxable year on indebtedness.”  Sec.             
          163(a).  Nevertheless, an individual is not entitled to a                   
          deduction for personal interest.  See sec. 163(h).  Certain                 
          interest, including “interest paid or accrued on indebtedness               
          properly allocable to a trade or business (other than a trade or            
          business of performing services as an employee)” is not personal            










Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011