Curtis Muhammad - Page 14

                                       - 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 of           










Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011