- 2 - any other court, and this opinion shall not be treated as precedent for any other case.2 Respondent determined a deficiency of $7,106 in petitioner’s 2001 Federal income tax. The sole issue for decision is whether petitioner is entitled to deductions for certain expenses claimed on Schedule C, Profit or Loss From Business, for the year at issue in excess of amounts allowed by respondent. That issue is premised on whether petitioner conducted a trade or business activity principally in his home. Some of the facts were stipulated. Those facts, with the annexed exhibits, are so found and are made part hereof. Petitioner’s legal residence at the time the petition was filed was Glen Burnie, Maryland. Background From 1974 to 1991, petitioner was an employee of the National Oceanic & Atmospheric Administration (NOAA), a Federal agency. Petitioner’s background is in naval navigation. He left his employment with NOAA in 1991 and commenced a self-employment activity which dealt essentially in the sale of charts, maps, nautical supplies, and navigational services to boat and yacht owners. Petitioner discontinued that activity around 1996 and reestablished a relationship with NOAA as an independent 2 Unless otherwise indicated, subsequent section references are to the Internal Revenue Code in effect for the year at issue.Page: Previous 1 2 3 4 5 6 7 8 NextLast modified: March 27, 2008