- 13 - September 2002, he was being trained as a financial adviser for Waddell & Reed and worked out of an office in Langhorne, Pennsylvania. After September 2002, petitioner was assigned to a Waddell & Reed district office located in Philadelphia, Pennsylvania, where petitioner had a desk from which to work. Petitioner also testified that he received assistance from Chester Muhammad in setting up a limited liability company for his rental real estate, but petitioner failed to establish that he actually operated this enterprise from his basement. In terms of working in a business, petitioner refers mostly to his job as a financial adviser for Waddell & Reed. The evidence and testimony indicate that petitioner’s principal place of business was the office of Waddell & Reed, in Langhorne, Pennsylvania, until September 2002, and in Philadelphia, Pennsylvania, for the rest of 2002. We find that petitioner has failed to establish that his basement was his principal place of business in 2002. Because petitioner has failed to meet the requirements necessary to apply a section 280A(c)(1) exception to the general rule of section 280A(a), it is unnecessary to examine whether petitioner substantiated the expenses he deducted in relation to the purported business use ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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