Frank H. and Marla C. Black - Page 30

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               Section 280A(a) provides as a general rule that no deduction           
          otherwise allowable to an individual “shall be allowed with                 
          respect to the use of a dwelling unit which is used by the                  
          taxpayer during the taxable year as a residence.”  As relevant              
          herein, section 280A(c)(1) provides that the general rule of                
          section 280A(a) is not applicable to any item to the extent it is           
          allocable to a portion of the dwelling unit which is exclusively            
          used on a regular basis as the principal place of business for              
          any trade or business of the taxpayer, or as a place of business            
          which is used by patients, clients, or customers in meeting or              
          dealing with the taxpayer in the normal course of his trade or              
          business.  Expenses deducted as a business use of home must be              
          deductible under section 162 or some other Code section.  See               
          sec. 280A(a).                                                               
               Petitioners claimed Schedule C deductions for eight checks             
          written to their daughter Anita.  We conclude, largely on the               
          basis of Agent O’Dell’s interview with Anita on September 6,                
          1995, that such checks to Anita were gifts of money and supplies            
          for her college work.  The checks to Anita were not properly                
          deductible as business expenses.                                            
               Petitioners also claimed Schedule C deductions on their                
          joint 1991 and 1992 returns for payments to their two young                 
          children, Dominique and Jonathan.  Petitioners contend that                 

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