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sales of goods delivered to IBC customers. IBC had the right to
discharge petitioner for certain infractions specified in the
union agreement. IBC provided petitioner with paid holidays,
vacations, and sick and funeral leave. In addition, IBC provided
petitioner with severance pay benefits and coverage under pension
and health benefit plans. Normally, petitioner’s sales route was
based on driver seniority.
Petitioner’s compensation from his activity was reported to
him and the Government by IBC as wages on a Form W-2, Wage and
Tax Statement. For 1997 and 1998, IBC reported wages of $45,700
and $42,940, respectively, to petitioner. For 1997 and 1998,
petitioners deducted $7,965 and $6,443, respectively, for home
office expenses. During the years in issue, one of the bedrooms
in petitioner’s home was converted into an office which he used
for budget tracking and promotional and other work. IBC did not
require petitioner to maintain an office in his home as a
condition of employment.
Respondent concedes that if the Court finds that petitioners
are not entitled to home office deductions under section 280A,
then petitioners are entitled to the following additional
deductions on Schedules A, Itemized Deductions, for 1997 and
1998:
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