- 27 - spent for personal purposes. Sutter v. Commissioner, 21 T.C. 170, 173 (1953). Petitioners did not produce any bills, canceled checks, or testimony to substantiate any portion of the expenses that relates to Mr. Schmidt’s separate farming business. Thus, petitioners have failed to establish that the Schmidts are entitled to a deduction for any portion of the expenses under section 162.8 4. Rental Value of Residence The Schmidts leased the Schmidt farm, including the farmhouse, from Hillside Dairy for $6,000. We are satisfied, on the basis of the property taxes for the farmhouse, that the fair rental value of the farmhouse for each year at issue did not exceed $6,000. 5. Summary of Adjustments to the Schmidts’ Income The following personal expenses paid by Hillside Dairy are included in the Schmidts’ income as constructive dividends for the years at issue: 8Except as otherwise provided, an individual is not allowed a deduction with respect to the use of a dwelling unit that is used by the individual as a residence. Sec. 280A(a). The individual, however, may deduct expenses allocable to portions of the dwelling that are exclusively used for business purposes. Sec. 280A(c). In the cases at bar, the Schmidts did not argue that the utility expenses are deductible under sec. 280A. Therefore, we do not address the question of whether any portion of the utility expenses may be deductible under that section. We note, however, that the Schmidts made no showing that the farmhouse, or any portion thereof, was used exclusively for business purposes.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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