Richard G. and Carolyn J. Newhouse - Page 13




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          is extraordinary that he would need to incur the expense to keep            
          and store a whole "library".                                                
               Petitioner has not established that the costs of                       
          commercially storing the books and other materials are deductible           
          business expenses.  The Court finds that petitioner collected               
          large amounts of books, maps, and other geographical materials              
          for personal reasons.  See Mann v. Commissioner, T.C. Memo. 1993-           
          201; Wheatland v. Commissioner, T.C. Memo. 1964-95.                         
               Focusing now on petitioners' home, they argue that they are            
          entitled to deduct a substantial portion of the cost of renting             
          the three-bedroom house in which they reside.  Section 280A                 
          generally prohibits deduction of otherwise allowable expenses               
          with respect to the use of an individual taxpayer's home.  As an            
          exception, this restriction does not apply to any item to the               
          extent such item is allocable to a portion of the dwelling unit             
          which is exclusively used on a regular basis as the principal               
          place of business for any trade or business of the taxpayer.                
          Sec. 280A(c)(1)(A).  In the case of an employee, the exclusive              
          use of a portion of the dwelling unit must be for the convenience           
          of his employer.  Sec. 280A(c).  Petitioner has not shown that              
          his home was used for the convenience of his employer.  See                 
          Gantner v. Commissioner, 91 T.C. 713, 730 (1988), affd. 905 F.2d            
          241 (8th Cir. 1990); Bowles v. Commissioner, T.C. Memo. 1993-222.           
          Nor has he shown that his principal place of business was other             






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