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artist, and petitioner Natalie Marselly was employed as a social
worker.
Throughout the years in issue, petitioners resided in the
same apartment, which they rented. A portion of petitioners’
apartment was used by petitioner Michael H. Visin for business
purposes.
In 1998, petitioner Michael H. Visin spent $3,450 for
computer equipment and software for use in his business. The
computer equipment and software were placed in service upon
purchase.
Petitioners filed a Form 1040, U.S. Individual Income Tax
Return, for each of the years in issue. Petitioners attached to
each of those returns a Schedule C, Profit or Loss From Business,
for petitioner Michael H. Visin’s sole proprietorship. Among the
deductions claimed on each Schedule C was a deduction for
petitioner Michael H. Visin’s use of petitioners’ apartment for
business purposes. In support of this deduction, petitioners
attached to each of their returns a Form 8829, Expenses for
Business Use of Your Home.
Petitioners’ Schedule C for 1997 included the following
entries:
Gross income $5,399.00
Less: expenses
(excluding rent) -4,392.40
1,006.60
Less: rent -10,305.27
Net loss ( 9,298.67)
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