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responsibility for stale or unsold goods and that he would
receive a full credit (be entitled to retain commissions) for
such merchandise.
At trial, petitioner explained that the cost of goods sold
adjustment was based on commissions that could have been earned
on products that were not sold because they were returned to IBC.
We are at a loss to understand how petitioner could have been
out-of-pocket for the cost of such items under these
circumstances, especially where IBC provided petitioner with a
credit for returned merchandise and IBC was required to pay
commissions to petitioner even if the customer returned the
merchandise.
D. Petitioner’s Entitlement to Home Office Expenses
On the 1997 and 1998 income tax returns, petitioner claimed
$7,965 and $6,443, respectively, as home office expenses.
Section 280A generally prohibits the deduction of the costs of a
taxpayer’s residence. Section 280A(c)(1), however, permits a
deduction for the allocable portion of a residence that is
regularly and exclusively used as a taxpayer’s principal place of
business or as a place of business which is used by customers in
the normal course of the taxpayer’s trade or business.
An employee is entitled to a home office deduction only if
such an office is required for the employer’s convenience.
Frankel v. Commissioner, 82 T.C. 318, 325-326 (1984). In that
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