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While we accept that petitioner used a portion of his
dwelling for consulting activities, we are unable to determine the
amounts, if any, of expenses he paid in connection with that
activity. The fact that petitioner contributed to general
household expenses does not suffice to convert those personal
living expenses into home office business expenses. Moreover, it
is not clear that any transfer of funds actually took place in the
first 9 months of 2003, and no other taxpayer (i.e., petitioner’s
daughter, who held title to the home, or his wife) reported any
rental income from the dwelling. In sum, petitioner has not
proven entitlement to any deduction for rent for the first 9
months of 2003 or to a deduction for utilities, telephone, or
Internet services.
For the last 3 months of 2003, petitioner moved his place of
business to different premises. Petitioner credibly testified
(and substantiated) that he paid rent of $600 per month for the
last 3 months of 2003 to an unrelated third-party landlord.
Petitioner is therefore entitled to a $1,800 deduction for a rent
expense in carrying on his consulting activity in 2003.
Petitioner claimed a $5,546 deduction for “mileage/travel”
expenses paid in connection with his consulting activity. In
support of the claimed deduction, petitioner submitted records
showing the number of miles he traveled each month and a
description of the purpose of the travel. The records were
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