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1990-483. Therefore, we hold that petitioner’s use of his home
for his book writing project does not qualify it as a home
office.5
Consistent with his treatment of a portion of his home as a
home office, petitioner claimed an $8,585 deduction for the use
of his passenger vehicle for business travel and transportation.
The claimed “travel expense” consisted of expenses petitioner
incurred in driving from his home to various libraries in the
State in order to gather material for his book, as well as the
expenses he incurred in driving from his home to his office at
the university. Even were we to hold that petitioner’s book
writing project was a separate business activity and that
petitioner maintained a home office, the deduction for these
claimed driving expenses would not be allowable because those
claimed deductions have not been adequately substantiated.
In general, all ordinary and necessary expenses paid or
incurred in carrying on a trade or business during the taxable
year are deductible. Sec. 162(a). An expense is considered
ordinary for these purposes if it is normal or customary within a
5Even were we to hold that petitioner’s book writing project
was separate from his employment as a university professor,
petitioner would still not be entitled to the claimed home office
deduction because sec. 280A(c)(5) would limit the amount of the
home office deduction to the amount of income produced from the
book. The parties do not dispute that in 2003, the tax year in
issue, petitioner had not yet written the book and therefore did
not have any income from the book writing project.
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