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allowed irrespective of whether the home was used for business.
Petitioner also failed to establish he conducted a separate
trade or business of making films or of composing and selling
music. Petitioner testified he produced no films in either 1996
or 1997, other than a few slide presentations in 1997 used in his
medical practice. Petitioner also failed to establish that
expenses relating to a separate trade or business of making films
or composing and selling music would have been allowable under
section 183 (which disallows losses from activities not engaged
in for profit).
Finally, petitioner failed to establish that his proposed
allocation of home expenses was appropriate. Petitioner’s
proposed allocation is based on an estimate of the portion of his
home used to store his film and music equipment. A deduction for
use of a home for storage of business property is allowed if the
dwelling is the “sole fixed location of such trade or business”
and is used as a “storage unit for the inventory or product
samples” of the taxpayer’s trade or business. Sec. 280A(c)(2);
Banatwala v. Commissioner, T.C. Memo. 1992-483. Petitioner used
his residence to store audio and video equipment used to make
films and music, not inventory held for sale to customers or
samples. Petitioner also failed to establish that his home is
the sole location of his trade or business. We therefore deny
petitioner’s request to deduct two-thirds or any portion of the
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