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regular basis as the principal place of business for any trade or
business of the taxpayer. See sec. 280A(c)(1)(A). Accordingly,
in order to qualify under section 280A(c), a portion of
petitioner’s dwelling must be exclusively used on a regular basis
as the principal place of business for his trade or business.
See Hamacher v. Commissioner, 94 T.C. 348, 353 (1990).
Petitioner has not established that he made expenditures or
that he allocated the expenses between personal and business use.
Petitioner did not provide any evidence of expenditures for the
home office. Petitioner testified that he paid $250 per week to
his friend to reside in her home, and she was entitled to use
these funds for any purpose. However, petitioner failed to
provide any substantiation beyond his testimony that the
expenditures were pursuant to a trade or business. Though
petitioner claims that a portion of this weekly payment included
expenses associated with the home office, he provided neither any
receipts showing the expenditures nor any evidence to indicate
any allocation of expenses. We need not examine the technical
requirements of section 280A(c) regarding the use of a portion of
a residence as a home office, because in any event petitioner has
failed to substantiate any home office expenses. Accordingly,
petitioner is not entitled to a home office deduction under
section 280A.
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