Lang Her & Ka Moua - Page 9

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          and had difficulty explaining how various items appearing on the            
          Schedules C were incurred.  For example, on the 2000 and 2001 tax           
          returns petitioner deducted $12,864 and $6,000, respectively, for           
          wages, but he had no evidence to substantiate these expenses.  Of           
          the total disallowed expenses relating to the insurance business            
          activity, the parties stipulated that petitioner was entitled to            
          a deduction of $1,330 for supplies for 2001.  With the exception            
          of the agreed item, respondent’s disallowance of the claimed                
          expenses on both the 2000 and 2001 Schedule C is sustained.                 
               Furthermore, generally no deductions are allowed with                  
          respect to the use of a dwelling unit which is used by the                  
          taxpayer as a residence.  Sec. 280A(a).  A taxpayer may be                  
          excepted from this general rule if a portion of the dwelling unit           
          is exclusively used on a regular basis “as the principal place of           
          business for any trade or business of the taxpayer”.  Sec.                  
          280A(c)(1)(A).                                                              
               Even assuming that petitioner’s Renaissance activities were            
          those of a trade or business and that petitioner’s basement was             
          used as the principal place of business, expenses incurred for              
          incidental or occasional use of a home office are not deductible.           
          See, e.g., Cally v. Commissioner, T.C. Memo. 1983-203; Roth v.              
          Commissioner, T.C. Memo. 1981-699.  Petitioners’ basement was               
          allegedly used for meetings only once every 2 weeks during the              
          second year of petitioner’s involvement with Renaissance.  From             






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