The rules for deducting
home office expenses can be expected to come under even greater scrutiny in the future as pressure arising from the need for child care, energy conservation and pollution abatement causes even more taxpayers to work out of their homes, either for themselves or their employers.
offering expenses, the total price to the public, underwriting discounts and commission and proceeds to the company are $531,700,000, $16,580,250 and $515,119,750, respectively.
Assuming all other requirements for deducting
points are met, the Browns can deduct 50% of the points, $3,000, in 1994 as prepaid interest attributable to home improvements.
the interest on the appropriate forms and/or lines is sufficient under the regulations to perfect the election, taxpayers are advised to make the election in a separate statement attached to the return.
Most intangible assets are expected to benefit more than one year, so their cost is a capital expenditure under Internal Revenue Code section 167 (depreciation), the primary authority for deducting
If the taxpayer is counting on deducting
the interest, the taxpayer can easily manipulate the number of personal-use days.
As to deducting
interest on unsecured claims, the IRS contended that because of the debtor's financial condition, "full payment of principal let alone interest will not be made to .
469(a) prohibits individuals, estates, trusts, closely held C corporations and personal service corporations from deducting
passive activity losses or passive activity credits from nonpassive gains in an effort to lower taxable income.
The taxpayer made a number of arguments in favor of deducting
its loan origination costs as ordinary and necessary business expenses.
If combined, the disposition probably would not satisfy the disposition of "substantially all" of an activity for deducting
suspended passive losses.
Individual taxpayers residing in the Fourth, Sixth, Eighth and Ninth Circuits are barred from deducting
deficiency interest; the issue is more uncertain for taxpayers in other circuits.
The disallowance of the entertainment facility expenses was based solely on the statutory prohibition on deducting
entertainment facility expenses.