Edward L. and Terri L. Pyrdum - Page 8

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               Similarly, with regard to the other travel expenses,                   
          petitioner has no records indicating the business purpose of the            
          trips.  Petitioner testified that the trip to Buffalo, New York,            
          was to meet a “potential customer”, but there is no indication of           
          any business discussions.  While in preparation for the trial               
          petitioner wrote the name Davis Evans on the Columbus, Ohio,                
          hotel receipt, there again is no indication of any business                 
          discussions.  These records do not satisfy the adequate record              
          requirements of section 274, and we sustain respondent’s                    
          disallowance of the travel expense deductions.6                             
               Turning to the deductions claimed for “utilities”, as we               
          understand, petitioners claim that petitioner used a portion of             
          their home for her business.  For the 2000 taxable year                     
          petitioners also claimed a deduction for business use of their              
          home.  Section 280A(a) prohibits any deduction “with respect to             
          the use of a dwelling unit which is used by the taxpayer * * * as           
          a residence.”  A portion of a dwelling may be exempted from                 
          section 280A(a) if it 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).                                                



          6  Petitioner also introduced into evidence pages of a January              
          and December 2000 calendar and what she describes as customer               
          sheets containing the names, addresses, and telephone numbers of            
          potential customers.  Neither indicated whether she had any                 
          business meetings with these customers during her travels.                  





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