T.C. Memo. 2006-33
UNITED STATES TAX COURT
CHARLES E. AND SANDRA A. ANDERSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13228-04. Filed February 27, 2006.
Held: Because petitioners use a portion of their bed
and breakfast inn as their personal residence, the general
disallowance rule of sec. 280A(a), I.R.C., and the
exclusive-use limitation of sec. 280A(f)(1)(B), I.R.C., are
applicable, and expenses relating to the portion of the inn
that is used for both business and personal purposes (i.e.,
dual-use portion) are not allowable.
Mark S. Miller, for petitioners.
Jeremy L. McPherson and Daniel J. Parent, for respondent.
MEMORANDUM OPINION
SWIFT, Judge: Respondent determined a $1,434 deficiency in
petitioners’ 2000 joint Federal income tax.
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