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Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, 290 U.S.
111, 115 (1933). A taxpayer is required to maintain records
sufficient to substantiate his or her claimed deductions. Sec.
6001. This includes the burden of substantiating the amount and
purpose of the items claimed. Id.; Hradesky v. Commissioner, 65
T.C. 87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir.
1976).
Section 162(a) generally allows a deduction for ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on a trade or business. Section 262(a), however,
generally precludes deductions for personal, living, or family
expenses. Section 280A further disallows business expenses with
respect to the use of a dwelling unit used by the taxpayer during
the taxable year as a residence. Sec. 280A(a).
Section 280A(c), however, permits the deduction of expenses
allocable to a portion of the dwelling unit that is used
exclusively and on a regular basis as either: (1) The principal
place of business for the taxpayer’s trade or business, or (2) a
place of business that is used by clients or customers in meeting
or dealing with the taxpayer in the normal course of the
taxpayer’s trade or business. Sec. 280A(c)(1). In determining
whether a home office is a taxpayer’s principal place of
business, we must consider (1) the amount of time spent at each
location, and (2) the relative importance of the activities
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