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Thousand Oaks home. Consequently, expenses such as rent, repairs
and maintenance, utilities, and telephone associated with the
Thousand Oaks home are disallowed under section 262.
In the alternative, petitioner contends that he is entitled
to these expenses because he maintained a home office in the
Thousand Oaks home. Petitioner’s contention lacks merit.
Although we do not doubt that petitioner may have worked at
home on occasion with respect to his real estate activity, we
decline to accept petitioner’s naked assertion that the expenses
are valid business expenses without further supporting evidence
of the business purpose of the expenses or the correct allocation
between personal and business expenses. See Geiger v.
Commissioner, 440 F.2d 688 (9th Cir. 1971), affg. T.C. Memo.
1969-159. On the basis of the record, we find that petitioner’s
principal place of business for his real estate activity was his
office at Fred Sands and that petitioner maintained his home
office for his own personal convenience.
In addition, petitioner failed to present any evidence
whatsoever indicating the amount of time and the relative
importance of the activities that he performed at Fred Sands in
comparison to the Thousand Oaks home, and the extent to which he
used his home office for business in the normal course of his
real estate activity. In particular, we fail to see how
petitioner could have used the great room at Camino Cristobal
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