- 9 - Petitioner did not establish that he conducted substantial administrative or management activities of his trade or business at his home. Except for occasional telephone calls he received at home with respect to some of his work assignments, there was no other evidence presented that would satisfy the Court that petitioner's home was the situs of management or administrative activity related to his activity. Petitioner also contended that, because he stored equipment used in his business activity in a shed on his home premises, such fact entitles petitioners to a home office deduction. Section 280A(c)(1) provides, in pertinent part: (1) Certain business use.–-Subsection (a) shall not apply to any item to the extent such item is allocable to a portion of the dwelling unit which is exclusively used on a regular basis-- * * * * * * * (C) in the case of a separate structure which is not attached to the dwelling unit, in connection with the taxpayer's trade or business. However, none of the expenses petitioners claimed with respect to their home office related to the shed. All of the claimed expenses related to the room in petitioners' home. Petitioners, therefore, are not entitled to a deduction for home office expenses.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011