- 2 - The issue for decision is whether petitioners’ bed and breakfast inn is to be treated as a dwelling unit subject to the general disallowance rule of section 280A(a) and to the exclusive-use limitation of section 280A(f)(1)(B). If so, none of the expenses relating to the portion of petitioners’ bed and breakfast inn that is used for both business and personal purposes are allowable. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background The facts of this case have been fully stipulated by the parties under Rule 122 and are so found. At the time the petition was filed, petitioners resided in Sutter Creek, California. In April of 2000, petitioners purchased a bed and breakfast inn located in Sutter Creek (the Inn). From the time of its purchase, petitioners and petitioner Sandra Anderson’s parents have used a portion of the Inn as their personal residence, and, after making repairs and improvements, petitioners continued operating the Inn as a bed and breakfast under the name of “Eureka Street Inn”.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011