Edward L. and Terri L. Pyrdum - Page 9

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               We begin by noting that petitioners have no records showing            
          the total amounts paid for utilities.  For the 2000 taxable year            
          they claimed a deduction based on the business use of a portion             
          of the dwelling and for both years they claimed utility expenses            
          connected with this use.  According to a Form 8829, Expenses for            
          Business Use of Your Home, included in the 2000 tax return,                 
          petitioner used 14.81 percent of the home exclusively for her Key           
          Credit business.  If this were correct, petitioners’ total                  
          utility bills for 2000 would have been approximately $27,000                
          ($4,000 � .1481).  We decline to visit further into this land of            
          Oz.7  Respondent’s disallowance of the utility expenses is                  
          sustained.                                                                  
               Furthermore, petitioners have not substantiated that                   
          petitioner used a portion of the home exclusively for her                   
          business.  Petitioner-husband testified that the home office was            
          in the living room of the house.  But, there is nothing to                  
          indicate that exclusive use of that room was for the Key Credit             
          business.  Petitioners have not shown that the exception to                 
          section 280A(a) applies, and we sustain respondent’s                        
          determination.                                                              
               The remaining deductions for 1999 and 2000 were for                    
          supplies.  Again, petitioners have no receipts or other documents           


          7  According to petitioners, the utility records could not be               
          located.  We suspect that we know the reason for this.                      





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