- 8 - sections of the Code. He insisted that section 262, which prohibits the deduction of personal, living, or family expenses, applies only to businesses or corporations. He contended that section 535, which applies to accumulated taxable income for purposes of the corporate accumulated income tax, allows him to accumulate a certain amount of taxable income. Notwithstanding his purported familiarity with numerous Code sections, he failed to show that he qualified for deduction of any expenses that would be allowed if substantiated. There is no evidence in the record that any part of petitioner’s home was used exclusively and regularly for business or otherwise qualifies for an exception from the general rule of section 280A disallowing expenses of a dwelling unit used by the taxpayer as a personal residence. Although he presented a single document that apparently related to real property taxes on his residence, he presented no proof of payment, and the amount shown on the document as due in 2000 was substantially less than amounts that he claimed on his returns for 1999 and 2000. In summary, this is basically another case where a taxpayer claims that his wages are not taxable income. His arguments are indistinguishable from those that have been uniformly rejected, and no further discussion of them is warranted. See Lonsdale v. United States, 919 F.2d 1440 (10th Cir. 1990); United States v. Connor, 898 F.2d 942, 943 (3d Cir. 1990); United States v. Ward,Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011