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Our taxpayer/hypothetical client is engagedin a sales activity. She has been engaged in this activity for nine years. She is a manufacturer's representative, representing several

Our taxpayer/hypothetical client is engagedin a sales activity. She has been engaged in this activity for nine years. She is a manufacturer's representative, representing several accessory and jewelry designers and manufacturers. She is self-employed and has only one office.Her office is in her home. The office consists of a closed off area of the living room where the children are not supposed to play, but they do watch the television in there sometimes.She has samples stored there (one of a kind to show to customers - but not sold to customers).All items are sent to buyers directly from the designers and manufacturers. Client travels extensively using her own car to make visits to existing customers and potential customers. We obtained this information at our first meeting with her.We have not previously done any tax work for her.

  1. Is our hypothetical client entitled to deduct home office expenses? In what BNA Portfolio or Portfolios will you find your answer?
  2. For those of you who have concluded that the answer is "yes," what is your primary authority for your position that would support your conclusion?Treasury Regulations? Case law? Tax Court? Federal Appellate Court decisions? The materials in the research footnotes are a very important part of your research.

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