Ira S. Feldman and Susan B. Feldman v. Commissioner of Internal Revenue

SNEED, Circuit Judge:

The Commissioner of Internal Revenue appeals a decision of the Tax Court allowing the taxpayer, Ira S. Feldman, to deduct as business expenses the costs of producing income by renting to his accounting firm a room in his house, which he in turn used as a home office. We affirm.

I

FACTUAL AND PROCEDURAL BACKGROUND

Sometime in 1977, Ira S. Feldman (the taxpayer) and his wife contracted to purchase a home that was to be built to their specifications. The finished house had nine rooms and an adjacent two-car garage. On the second floor, across from the master bedroom suite,…