- 10 - significantly increased costs as a result of the business activity, and that the provision should be interpreted to carry out its objectives. * * * * * * * Explanation of Provision * * * * * * * Limitations on deduction In general.–-The bill limits the amount of a home office deduction (other than expenses that are deductible without regard to business use, such as home mortgage interest) to the taxpayer’s gross income from the activity, reduced by all other deductible expenses attributable to the activity but not allocable to the use of the unit itself. Thus, home office deductions are not allowed to the extent that they create or increase a net loss from the business activity to which they relate. [H. Rept. 99-426, at 133-135 (1985), 1986- 3 C.B. (Vol. 2) 133-135).] Finally, for petitioners’ benefit, we observe that to the extent deductions are disallowed under section 280A(c)(5), they may be carried forward to the succeeding taxable year. See sec. 280A(c)(5), flush language. In view of the foregoing, we hold that petitioners’ deductions for the business use of their apartment are subject to the limitation set forth in section 280A(c)(5). Accordingly, we sustain respondent’s determination in this regard. B. Election To Expense Certain Costs Under Section 179 Section 179(a) permits a taxpayer to: elect to treat the cost of any section 179 property as an expense which is not chargeable to capital account. Any cost so treated shall be allowed as a deduction for the taxable year in which the section 179 property isPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011