Feldman v. Commissioner
United States Tax Court
Petitioner maintained an office in his home that was rented to his employer for his own use. The employer, of which petitioner was a shareholder and director, paid $ 5,400 designated as rent to petitioner in 1979. Petitioner reported the rental income and deducted his costs of maintaining the leased space, which he calculated as 15 percent of his home.
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Petitioner maintained an office in his home that was rented to his employer for his own use. The employer, of which petitioner was a shareholder and director, paid $ 5,400 designated as rent to petitioner in 1979. Petitioner reported the rental income and deducted his costs of maintaining the leased space, which he calculated as 15 percent of his home. Held: The payments, to the extent they are reasonable, constitute rent, and, under sec. 280A(c)(3), I.R.C. 1954, the costs of producing that income may be deducted in accordance with sec. 280A(c)(5). Reasonable rental value and deductible…
1Opinion of the Court
Cohen, Judge:
Respondent determined a deficiency of $1,280 in petitioners’ 1979 Federal income taxes. The questions for decision are whether petitioners may deduct the costs of maintaining space in their home that is leased to petitioner Ira Feldman’s employer for Ira Feldman’s use as a home office, and, if so, what amounts are deductible.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.
Petitioners are husband and wife and resided in Phoenix, Arizona, during the year in…
2Cases cited9 opinions
- Place v. CommissionerUnited States Tax Court · 1951
- Sparks Nugget, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1972
- Bolton v. CommissionerUnited States Tax Court · 1981
- Dorance D. And Helen A. Bolton v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Davis v. CommissionerUnited States Tax Court · 1956
4 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Ira S. Feldman and Susan B. Feldman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Rodriguez v. Comm'rUnited States Tax Court · 2009
- FMC Corp. v. CommissionerUnited States Tax Court · 1993
- Stewart v. CommissionerUnited States Tax Court · 1987
- Andrews v. CommissionerUnited States Tax Court · 1990
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