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deduction may be allowed to the extent that the item is allocable
to a portion of the home which is exclusively used on a regular
basis as the principal place of business for the taxpayer’s trade
or business. Sec. 280A(c)(1)(A).
Petitioners argue that 43 percent of their residence was
used exclusively for business purposes; we find that 12.7 percent
of the residence was so used. We reject petitioners’ argument
that portions of the middle and bottom floors and the garage were
used exclusively for business: Certain areas purportedly were
set up for use by Ms. Brayshaw, who was not engaged in her
medical business in the year in issue. Other areas contained
inherently personal items, such as a fireplace and sofas, or were
for storage which was not necessarily related to Mr. Brayshaw’s
businesses. Finally, we have found that the Jeep was not used
exclusively for business purposes; consequently, the garage in
which it was stored likewise was not so used. On the other hand,
we accept Mr. Brayshaw’s testimony–corroborated by photographs--
that portions of the top floor were used exclusively as his
principal place of business with respect to his several
businesses. We therefore find that 228.75 square feet, of the
total 1,804.32 square feet, were used exclusively and regularly
as Mr. Brayshaw’s principal place of business. Petitioners are
entitled to deductions for the applicable percentage of the
following substantiated expenses which were paid by petitioners:
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