Irwin and Jeannine Radnitz - Page 8




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          the door.”  He used the North Indian Avenue apartment to work on            
          a script called "In for the Kill" from March through May 1998.              
          He used the Ravenspur apartment from September through November             
          1998 to finish and rewrite that script.  Prior to Mr. Radnitz’s             
          use of the Ravenspur apartment, Mrs. Radnitz used it from March             
          through August 1998.  Mr. Radnitz explained that the earlier “use           
          of that site was by my wife who is pursuing her career as an                
          actress, and it was used as her office.”  No further evidence of            
          Mrs. Radnitz’s use was provided at trial; however, petitioners              
          claimed no deductions for Mrs. Radnitz’s use of the Ravenspur               
          space during this time period.                                              
               During 1997, when Mr. Radnitz used his two residences (Vista           
          Loma and Deepak) as offices for his writing activity, petitioners           
          determined that 20 percent of the floor space of each home was              
          devoted to the home office.  Respondent has not challenged this             
          determination.  Based on expenses for both homes totaling $30,002           
          for 1997, petitioners deducted 20 percent of that amount less an            
          additional 10 percent of the resulting figure “for possible                 
          overage”.3  Thus, on the 1997 return, petitioners claimed a                 
          deduction for an office in the home of $5,400.  In the notice of            
          deficiency, respondent allowed petitioners a $980 home office               


               3    The total annual home expenses of $30,002 for 1997                
          consisted of rent, $22,400; gas, $2,268; electricity, $3,852;               
          water, $876; television cable, $540; and disposal, $66.                     





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