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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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