Hamacher v. Commissioner
United States Tax Court
P used a room in his apartment only for business-related activities. One activity concerned that of an employee who was already provided with an office and the other activity concerned independent contractor status where a relatively large percentage of the activity took place at the home office. P claimed the allocable portion of his rent as a deductible expense and he also claimed automobile expenses for travel to and from his home office.
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P used a room in his apartment only for business-related activities. One activity concerned that of an employee who was already provided with an office and the other activity concerned independent contractor status where a relatively large percentage of the activity took place at the home office. P claimed the allocable portion of his rent as a deductible expense and he also claimed automobile expenses for travel to and from his home office. R disallowed all expenses claimed with respect to the home office and a portion of the claimed automobile expenses as personal nondeductible…
1Opinion of the Court
GERBER, Judge:
Respondent, in a statutory notice of deficiency dated March 11, 1988, determined deficiencies in petitioners’ 1983 and 1984 Federal income tax in the respective amounts of $863.44 and $838. The deficiencies resulted from the disallowance of home office and automobile expense deductions related to petitioner Alfred W. Hamacher’s activities involving theater and acting. After concessions, the issues presented for our consideration are: (1) Whether petitioners are entitled to deductions for home office expenses under section 280A;1 and (2) whether petitioners are entitled to…
2Cases cited13 opinions
- Sharon v. CommissionerUnited States Tax Court · 1976
- Joel A. Sharon and Ann L. Sharon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
- Baie v. CommissionerUnited States Tax Court · 1980
- George H. And Sarah Newi v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Ernest Drucker, Patricia Rogers, Philip Cherry and Ruth Cherry, Petitioners v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1983
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3Cited by30 opinions
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- Brown v. Comm'rUnited States Tax Court · 2010
- Burch v. Comm'rUnited States Tax Court · 2011
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