David D. Brayshaw and Nora D. Brayshaw - Page 17




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                  Miscellaneous expenses                                                               
                  Petitioners argued at trial that numerous miscellaneous                              
            expenses are deductible.  These expenses include rentals of post                           
            office boxes, postage, shipping expense, copying expense, a New                            
            York Times newspaper subscription, business cards, office                                  
            supplies, hardware, telephone lines, and telephone calls.  Some                            
            of these items, in particular the newspaper subscription and                               
            certain of the telephone lines, are personal expenses and are                              
            nondeductible under section 262(a).  With respect to the                                   
            remaining items, either no business purpose is evident, the                                
            expenses were paid with corporate funds, or they were hybrid                               
            corporate/non-corporate/personal expenses which we could not                               
            disentangle.  We therefore hold that petitioners are not entitled                          
            to a deduction for any of these expenses.                                                  
                  Home office expenses                                                                 
                  Petitioners argue that various expenses related to their                             
            residence are deductible due to business use of a portion                                  
            thereof.  These expenses include depreciation, gas, electricity,                           
            water, sewer, refuse, repairs, property tax, condominium fees,                             
            and mortgage interest.                                                                     
                  Deductions for expenses attributable to a taxpayer’s                                 
            business use of his home are disallowed unless they fit within                             
            the exceptions enumerated in section 280A. Sec. 280A(a).  The                              
            exception applicable to the case at hand is the following:  A                              






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