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head of household filing status based on his claim that he
provided a household for his daughter Jamie. Jamie was born on
April 16, 1977. During 1996 and 1997, Jamie was a full-time
student at Penn State University. During these years, Jamie
remained at Penn State University for the summer months as a
participant in the ROTC program.
Respondent determined that the Camelot Inn was not an
activity engaged in for profit within the meaning of section 183.
For the taxable years 1996 and 1997, respondent disallowed the
deductions for Schedule C expenses claimed by petitioner with
respect to the bed and breakfast activity of $57,457 and $53,223,
respectively. Respondent allowed petitioner Schedule A
deductions for taxes which had been claimed on his Schedules C of
$1,810 and $4,568 for 1996 and 1997, respectively, plus an
additional deduction in 1996 of $3,545 for State taxes withheld.
Respondent also allowed petitioner Schedule A deductions for
mortgage interest which had been claimed on his Schedules C in
1996 and 1997 of $6,744 and $6,368, respectively. Respondent
allowed miscellaneous deductions of $958 and $3,880, for 1996 and
1997, respectively, for the remaining expenses deducted on his
Schedules C. Respondent also determined that petitioner did not
qualify for head of household filing status for the taxable years
in issue.
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