Cousino v. Commissioner

1981 T.C. Memo. 19, 41 T.C.M. 722, 1981 Tax Ct. Memo LEXIS 718
CourtUnited States Tax Court
DecidedJanuary 26, 1981
DocketDocket No. 9620-79.
StatusUnpublished

This text of 1981 T.C. Memo. 19 (Cousino v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cousino v. Commissioner, 1981 T.C. Memo. 19, 41 T.C.M. 722, 1981 Tax Ct. Memo LEXIS 718 (tax 1981).

Opinion

PAUL W. COUSINO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cousino v. Commissioner
Docket No. 9620-79.
United States Tax Court
T.C. Memo 1981-19; 1981 Tax Ct. Memo LEXIS 718; 41 T.C.M. (CCH) 722; T.C.M. (RIA) 81019;
January 26, 1981.
Paul W. Cousino, pro se.
James R. Rich, for the respondent.

FEATHERSTON

MEMORANDUM FINDINGS OF FACT AND OPINION

FEATHERSTON, Judge: Respondent determined a deficiency in the amount of $ 509 in petitioner's 1976 Federal income tax. The issues for decision are:

1. Whether petitioner is entitled to deduct expenses attributable to the use of his home office; and

2. Whether petitioner is entitled to deduct such expenses as an adjustment to gross income.

FINDINGS OF FACT

Petitioner Paul W. Cousino was a legal resident of Sterling Heights, Michigan, when he filed his petition. He timely filed his Federal income tax return for 1976.

During 1976, petitioner was employed as a junior high school social studies teacher by the Utica, Michigan, school system. During this same period, petitioner also served on the Board of Trustees for Macomb County Community College. Petitioner, who was elected to this latter position, received no compensation*721 for his services. The board held regular monthly meetings as well as many special meetings on one of two campuses. Petitioner's position as a trustee at the college was unrelated to his employment as a junior high school teacher.

During 1976, petitioner was required by the terms of his teaching employment contract to be at school for over 7 hours. While at school, petitioner was assigned a classroom containing shelves, a filing cabinet, and a desk where he could sit and work. In addition, petitioner had access to a vacant office in the school. This office contained a telephone and was generally available to teachers and visiting specialists, such as the school psychologist.

Petitioner lived in a mobile home during the year in issue. Although not required by his employment contract, petitioner apportioned part of the space of his home as an office. He used the office in connection with his teaching position to prepare lessons, communicate with parents, and grade papers. Petitioner also used his home office for his duties as a trustee such as answering and making telephone calls, reading correspondence, and preparing for board meetings. The office contained a television*722 set.

On his 1976 Federal income tax return, petitioner claimed various expenses, including those attributable to his home office as an adjustment to gross income. He based the amount of the home office deductions upon the percentage of the mobile home that the office comprised. In his notice of deficiency, respondent disallowed the deductions to the extent they were attributable to petitioner's home office.

OPINION

Congress enacted section 280A1 to limit the deductions for expenses of an office in the home. Effective for taxable years beginning after December 31, 1975, that section provides the general rule that "no deduction otherwise allowable under this chapter shall be allowed with respect to the use of a dwelling unit which is used by the taxpayer during the taxable year as a residence." Sec. 208A(a). An exception to this rule, however, is set out in section 280A(c)(1) as follows:

(1) Certain business use.--Subsection (a) shall not apply*723 to any item to the extent such item is allocable to a portion of the dwelling unit which is exclusively used on a regular basis--

(A) as the taxpayer's principal place of business,

(B) as a place of business which is used by patients, clients, or customers in meeting or dealing with the taxpayer in the normal course of his trade or business, or

(C) in the case of a separate structure which is not attached to the dwelling unit, in connection with the taxpayer's trade or business.

In the case of an employee, the preceding sentence shall apply only if the exclusive use referred to in the preceding sentence is for the convenience of his employer.

Petitioner first argues that he used his home office in connection with his duties as a junior high school teacher. For petitioner to be entitled to a home office deduction, he must show that his office was exclusively used on a regular basis for one of the three purposes enumerated in section 280A(c)(1). Moreover, because petitioner was an employee, he must also show that the use of the office was for the convenience of his employer. We hold that petitioner fails to qualify for the home office deduction under these requirements.

*724 It is clear that the home office was not a separate structure from his dwelling unit. Sec. 280A(c)(1)(C). It is also clear that petitioner's principal place of business was the school where he taught rather than his home office. Sec. 280A(c)(1)(A). Petitioner was provided with his own classroom as well as access to another office at the school. Further, petitioner's employment contract required his presence at the school for over 7 hours a day.

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Gerald W. Frank v. United States
577 F.2d 93 (Ninth Circuit, 1978)
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207 F. Supp. 866 (W.D. Missouri, 1962)
Kurkjian v. Commissioner
65 T.C. 862 (U.S. Tax Court, 1976)

Cite This Page — Counsel Stack

Bluebook (online)
1981 T.C. Memo. 19, 41 T.C.M. 722, 1981 Tax Ct. Memo LEXIS 718, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cousino-v-commissioner-tax-1981.