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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.
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Last modified: May 25, 2011