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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 of
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