Charles E. & Sandra A. Anderson - Page 1

                                 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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