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exclusively for business in light of the fact that the great room
comprised of the living room and dining room, and for most of the
year, petitioner’s girlfriend lived with him. With respect to
the Moorpark home, petitioner did not present any testimony or
documentary evidence of the extent to which he may have used the
second bedroom as an office. Thus, petitioner has not proven
that the expenses associated with the Thousand Oaks home were
deductible under sections 162 and 280A, rather than nondeductible
personal, living, or family expenses. See, e.g., Graves v.
Commissioner, 88 T.C. 28, 38 (1987); Hynes v. Commissioner, 74
T.C. 1266, 1289 (1980). Accordingly, we sustain respondent’s
determination on this issue.
III. Conclusion
We have considered all of petitioner’s arguments, and, to
the extent that we have not specifically addressed them, we
conclude that they are without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect our disposition of the disputed issues, as well
as the parties’ concessions,
Decision will be entered
under Rule 155.
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