- 10 -
said, and did not want to "move in and get all set up, because
one never knew how long you'd be there."
Petitioner testified that he kept in the storage spaces
books, maps, globes, bookcases, file cases, desks, "and so on
like that." Petitioner further testified that "there is some
personal aspect to each of them" but that if he did not have all
of his teaching material in there: "I would find a way of
stuffing the small amount of personal stuff in the warehouses
into the house."
Petitioner testified that he treated 85 percent of the
rental payments on his three-bedroom house as a business expense.
According to petitioner, "Most of the home is a library, and/or
office, or storage for various books, maps, globes, atlases, air
photos." His view, according to his testimony, is that geography
is "in effect, the world and everything that's in it, and to some
extent, that is why I have such a large library."
The Court accepts, for the purposes of argument, that
petitioner's home is used primarily as a storage place for
various books, maps, and globes. Petitioner, however, has not
shown that the rental expense of the storage spaces was ordinary
and necessary. See sec. 162(a); Welch v. Helvering, 290 U.S. 111
(1933).
Section 162 allows a deduction for ordinary and necessary
expenses paid or incurred by a taxpayer in carrying on a trade or
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011