Detailed Analysis
I. Introduction
A. Overview
B. Legislative History
C. Structure of Section 280A
II. Section 280A(a) Disallowance of Deductions Attributable to Business Uses of a Home
A. Home Expense Deductions Generally Disallowed
B. Taxpayers Subject to Section 280A
1. Generally
2. Partnerships
3. S Corporations
4. Trusts
C. Property Subject to Section 280A
1. Dwelling Unit
a. Single Structure with Multiple Dwelling Units
b. Appurtenant Property
c. Hotel Exception
(1) Property Regularly Available for Occupancy by Paying Customers
(2) Personal Use Prohibited
(3) Rental Pools
2. Residence
a. General Rule for a Residence
b. Exception for Qualified Rental of Principal Residence
(1) “Principal Residence†Defined
(2) Difference Between “Principal Residence†and “Residenceâ€
(3) Portion of Unit Not Used as Principal Residence
(4) Involuntary Conversion of Principal Residence
c. Separate Structure
D. Personal Use that Subjects a Taxpayer to § 280A Disallowance Rule
1. Use by Taxpayer
2. Personal Use - Attribution Rules
a. Use by Co-Owner
b. Use by Family Members
c. Reciprocal Arrangements - Unit Swapping
d. Bargain Rentals
e. Time Sharing and Rental Pool Use
(1) Time Sharing Arrangements
(2) Rental Pools
(3) Rental Pool Averaging Election
f. Personal Use from Charitable Donation of Use of Dwelling Unit
g. Personal Use by Pass-Through Entity
3. Exceptions to Attribution Rules
a. Rental at Fair Value
b. Shared Equity Financing Agreement
4. Excluded Uses: Holding for Rent, Repair and Maintenance
5. Documenting Personal Use
III. Exceptions to § 280A Disallowance Rule
Introductory Material
A. Exception for Expenses Deductible Regardless of Business Use of Home
B. Exception for Certain Business Use of Home
1. Trade or Business Requirement
a. Multiple Businesses
b. Investment Activity
2. Regular Use
3. Exclusive Use
a. De Minimis Personal Use
b. Dedicated Room
c. Separately Identifiable Space
d. All Uses Must Qualify
4. Qualifying Uses that Must Be Regular and Exclusive
a. Principal Place of Business
(1) Multiple Businesses
(2) Administrative or Managerial Activities as a Principal Place of Business
(3) Principal Versus Secondary Place of Business
(a) Pre-1976 Law
(b) Prior Law: Focal Point Test
(c) Soliman v. Comr.
(i) Lower Court Decisions
(ii) Supreme Court Opinion
(iii) IRS Response to Soliman
(iv) Scope of the Soliman Decision
(v) Post-Soliman Decisions
(d) 1997 Amendment to § 280A - Overruling Soliman on Its Facts
b. Place for Meeting or Dealing with Patients, Clients or Customers
5. Separate Structure Not Attached to Dwelling Unit
6. Qualifying Uses That Must Be Regular, But Need Not Be Exclusive
a. Certain Storage Use of Home
b. Day Care Services
(1) General Requirements
(2) Special Rule for Allocation of Day Care Expenses
7. Restriction on Employee's Ability to Deduct Home Business Expenses
a. Convenience of the Employer Required
b. Rental to Employer
C. Exception for Rental Use of Home or Vacation Home
1. The Requirement of Personal Use Applied to Rental Units
2. Taxpayer Must Charge Fair Rental
3. Allocation of Expenses Between Business and Personal Use
a. Items Included in Rental Expenses
b. Rental Expense Allocation Formula
c. Expenses Allocable to Renting a Portion of Unit
4. Rental Expenses and the Gross Income Limitation
a. Gross Rental Income
b. Exception for Qualified Rental Period of a Principal Residence
5. Special Rule for De Minimis Home Rental
IV. Additional Requirements for Expenses Allowable Under § 280A
Introductory Material
A. Expenses Must Be Allowed with Respect to a Dwelling Unit
B. Expenses Must Be Allocated Between Business and Personal Use
1. Direct Expenses
2. Indirect Expenses
3. Unrelated Expenses
C. Gross Income Limit: The “Tier System†of Priority for Deducting Home Business Expenses
1. Tier 1 - Otherwise Allowable Deductions: Interest, Taxes, Casualty Losses, etc.
2. Tier 2 - Activity Expenses Not Related to Home Use
3. Tier 3 - Operating Expenses Less Than Gross Income
4. Tier 4 - Depreciation Less Than Gross Income
5. Examples
D. Expense of First Telephone Line into Home Not Deductible
E. Coordination with Trade or Business Travel Expense
V. Disposition of Property for which Expenses under § 280A Have Been Deducted
Introductory Material
A. Bifurcation Requirement for Dual-Use Property
B. Sale of Principal Residence
1. Business Use
a. Prior Law - Former § 1034
b. Current Law - § 121
(1) Exclusion of Gain
(2) Recognition of Depreciation Taken After May 6, 1997
2. Rental Use
a. Interaction with § 121
b. Bargain Rental
c. Gain or Loss from Rental Unit
VI. Interaction of § 280A with Other Code Provisions
A. Interplay with § 183 Hobby Loss Rule
B. Interplay with § 469 Passive Activity Loss Rules
C. Interplay with § 465 At-Risk Limits
D. Interplay with § 163(h) Limitation on Home Mortgage Interest Deduction
E. Effect of § 67 Floor Under Miscellaneous Itemized Deductions and § 68 Overall Limit on Itemized Deductions
F. Section 280A Does Not Limit Business Travel Deductions
VII. Compliance
A. Heavy Burden on Taxpayer to Establish § 280A Deductions
B. Home Business Deductions by Employees
C. Home Business Deductions by Self-Employed Persons
D. Home Rental Deductions
Working Papers
Table of Worksheets
Worksheet 1 Committee Reports Excerpts on § 280A - Business Use of Home; Vacation Homes
Worksheet 2 [Reserved]
Worksheet 3 [Reserved]
Worksheet 4 [Reserved]
Worksheet 5 [Reserved]
Worksheet 6 Illustrative Shared Equity Financing Agreement
Worksheet 7 Illustrative Letter Regarding Convenience of Employer
Worksheet 8 Illustrative Residential Lease Involving Business Use of Home
Worksheet 9 Illustrative Contract for Goods or Services
Worksheet 10 Illustrative Independent Contractor Agreement
Bibliography
OFFICIAL
Internal Revenue Code:
Public Laws:
Legislative History:
Treasury Regulations:
Treasury Rulings:
Cases:
UNOFFICIAL
Tax Service:
Periodicals:
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