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Petitioner has 24-hour access to the office at NIRC. NIRC does
not require petitioner to maintain an office in the home.
Petitioners did not keep receipts or records for any of their
expenses associated with the office in the home, and petitioners
used an inflated basis in calculating depreciation expenses.
Petitioners claimed deductions for expenses relating to
maintaining the office in the home in 1996 and 1997.
On their 1991, 1994, and 1995 Federal income tax returns,
petitioners claimed deductions for estimated employment expenses,
investment expenses, charitable contributions, and office in the
home expenses that are similar to those claimed during the years
in issue. Petitioners prepared all of the tax returns themselves
without the assistance of a paid tax return preparer. Respondent
examined petitioners’ 1991 income tax return and issued a notice
of deficiency. Petitioners filed a timely petition with the
Court, and, on October 20, 1994, a stipulated decision was
entered.
OPINION
Respondent argues that petitioners are not entitled to the
deductions claimed on their returns because petitioners did not
provide any substantiation for the amounts reported. Petitioners
assert that they are entitled to the claimed deductions; however,
for the most part, they offered no books or records to prove that
they expended the amounts in question. Only petitioner Aziz A.
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