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to substantiate her claimed car and truck expenses. Mrs. Butler,
however, provided the Court with a list of her purported business
expenses. Also, included was a copy of a check made payable to
“WV Board of Respiratory Care” of $55. We believe Mrs. Butler’s
testimony that she incurred other license expenses and continuing
education credits of $95 and $260. However, when questioned as
to the amounts claimed for the remaining business expenses on her
Schedule C, Mrs. Butler’s testimony was vague.
Furthermore, with regard to Mrs. Butler’s deductions for her
business use of her personal residence, section 280A is
controlling. Under section 280A, the general rule is that,
except as provided by this section, no deduction is allowable
unless an allocable portion of the residence is exclusively used
as the principal place of any business activity conducted by the
taxpayer. All deductions allowable to the business use of the
residence must be used to offset the amount of gross income from
the business activity and is subject to the 2-percent floor on
miscellaneous itemized deductions. Sec. 280A(a), (c)(1), (c)(5).
We have taken into consideration Mrs. Butler’s testimony and
the handwritten list of claimed Schedule C expenses. We conclude
that petitioners are entitled to a business deduction totaling
$410. However, we cannot estimate any amounts for petitioners’
other business deductions under the Cohan rule. Sec. 6001; sec.
1.6001-1(a), (e), Income Tax Regs.
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Last modified: May 25, 2011