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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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