Legal Opinion

Anderson v. Comm'r

United States Tax Court

Decided February 27, 2006No. 13228-04Unpublished

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

  1. Crane v. CommissionerSupreme Court of the United States · 1947
  2. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  3. Lofstrom v. Comm'rUnited States Tax Court · 2005
  4. Richard A. Grigg and Mary G. Grigg v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1992
  5. Byers v. CommissionerUnited States Tax Court · 1984

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