Brian E. & Marcie L. Mallin - Page 5




                                        - 4 -                                         
          conversion, they installed a furnace in the workshop.                       
          Petitioners then spent $18,123 building a new garage in which to            
          house their vehicles.                                                       
               Making and selling chairs did not go well in Wyoming, so               
          petitioners tried their hands at wood signs and carved duck                 
          decoys.  They also gave away beaded keychains as a promotional              
          item for their woodworking business.  Ultimately, petitioners               
          terminated their woodworking business in 2003.                              
                                     Discussion                                       
               Although only two principal issues remain in the case, we              
          discuss all of the adjustments made in the notice of deficiency             
          for the sake of clarity.                                                    
          1.  Schedule C--2001                                                        
               After discussion and elaboration at trial, it became clear             
          that the bead and decoy expenses denied by respondent were                  
          incurred by petitioners as part of their woodworking business,              
          and we find for petitioners on those items.                                 
          2.  The Wyoming Workshop                                                    
               Petitioners claimed deductions on their Federal income tax             
          returns for the years 2001, 2002, and 2003 related to the furnace           
          installation in, and business use of, the Wyoming workshop.                 
          Unfortunately for petitioners, any deductions related to the                
          business use of the Wyoming workshop are limited by the                     
          provisions of section 280A(c)(5).  See also Rule 142(a); INDOPCO,           







Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next 

Last modified: March 27, 2008