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this record, it does not appear that petitioner devoted
substantial time and energy to any business activity that
involved the regular use of his basement. Petitioners have not
established that the exception to section 280A(a) applies, and
respondent’s disallowance of the deductions for utilities and
other expenses claimed for the home office is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011