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petitioner must show that the expenses were of the type expected
to be incurred in his business and were not personal expenses
incurred for pleasure. See Noyce v. Commissioner, supra at 687;
Marshall v. Commissioner, supra. Petitioner must also establish
that the expenses were reasonable under the circumstances. This
requires petitioner to establish that the expenses did not exceed
the income earned or expected from the activity. See Noyce v.
Commissioner, supra at 687-688. Petitioner failed to show that
he generated a profit from having a Burbank office. In
particular, he did not show that his Friday afternoon trips to
Burbank were made for business and not personal purposes.
Petitioner has failed to establish his entitlement to the
deductions for airplane expenses. Therefore, petitioner’s
request to deduct airplane expenses is denied.
Home Office Deduction
Petitioner seeks to deduct two-thirds of the expenses of
maintaining his home (including his mortgage payments, both
principal and interest, taxes, insurance, and utilities) as
above-the-line business expenses under sections 162(a) and 280A.
Petitioner has already been allowed an itemized deduction for
mortgage interest and real estate taxes. The repayment of
mortgage principal is, of course, not deductible. Commissioner
v. Tufts, 461 U.S. 300, 307 (1983). Petitioner appears to be
seeking a double deduction, which, of course, is not permissible.
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