Hamacher v. Commissioner
United States Tax Court
94 T.C. 348 (1990)
- Written by Kelsey Libby, JD
Facts
Alfred Hamacher (plaintiff) worked for the Alliance Theatre in Atlanta, Georgia, in two roles: as an independent contractor performing in plays and as an employee teaching theater and serving as an administrator for the theater’s acting school. Hamacher used two offices in connection with his work for the theater. First, the theater provided an office Hamacher could use for his employment duties that was shared with other employees. Second, Hamacher had a home office where he spent about half of his rehearsal time for stage roles (the other half took place at the rehearsal hall) and performed some portion of his employment duties when he wanted to avoid interruptions. The theater did not require that Hamacher maintain a home office. Hamacher spent more time working at the theater office than at his home office. Hamacher deducted expenses related to the home office, and the commissioner of internal revenue (defendant) disallowed the deduction. Hamacher petitioned the tax court for review.
Rule of Law
Issue
Holding and Reasoning (Gerber, J.)
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