Anderson v. Comm'r
United States Tax Court
Held: Because petitioners use a portion of their bed and breakfast inn as their personal residence, the general disallowance rule of sec. 280A(a), I.R.C., and the exclusive-use limitation of sec. 280A(f)(1)(B), I.R.C., are applicable, and expenses relating to the portion of the inn that is used for both business and personal purposes (i.e., dual-use portion) are not allowable.
1Opinion of the Court
CHARLES E. AND SANDRA A. ANDERSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Anderson v. Comm'r
No. 13228-04
United States Tax Court
T.C. Memo 2006-33; 2006 Tax Ct. Memo LEXIS 33; 91 T.C.M. (CCH) 791;
February 27, 2006, Filed
Held: Because petitioners use a portion of their bed and
breakfast inn as their personal residence, the general
disallowance rule of sec. 280A(a), I.R.C., and the exclusive-use
limitation of sec. 280A(f)(1)(B), I.R.C., are applicable, and
expenses relating to the portion of the inn that is used for
both business and personal purposes (i.e., dual-use portion) are
not…
2Cases cited5 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Lofstrom v. Comm'rUnited States Tax Court · 2005
- Richard A. Grigg and Mary G. Grigg v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1992
- Byers v. CommissionerUnited States Tax Court · 1984