- 26 - the record, we conclude that petitioner has adequately established entitlement to the claimed subscription expense. 11. Home Office Expenses Petitioner claims home office deductions of $1,867 and $1,996 for taxable years 1989 and 1990, respectively. Petitioner alleges that because there was no office space at Great Lakes available to him, he used space in his home as the principal place of business for his aviation activities. Respondent denies that petitioner’s residence constituted the principal place of business for petitioner’s aviation activities. Accordingly, respondent has disallowed petitioner any deduction for home office expense. Generally, an individual taxpayer may not deduct expenses with respect to a dwelling unit that the taxpayer uses as a residence during a taxable year. See sec. 280A(a). This general rule does not apply, however, where the taxpayer uses a portion of the residence regularly and exclusively as either: (1) The taxpayer’s principal place of business, or (2) a place of business which is used by clients or customers in meeting or dealing with the taxpayer in the normal course of the taxpayer’s business. See sec. 280A(c)(1)(A) and (B).14 Petitioner does not allege that he met clients at his home; rather, he contends that 14 The exception provided in sec. 280A(c)(1)(C) is inapplicable, as petitioner has not alleged that he used any separate structure not attached to his dwelling unit.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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