Renting Your Home Fewer Than 15 Days — IRC Section 280A(g) (the "Augusta Rule")

Source [7] The business-meeting strategy — and its documentation burden

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A common planning use: the owner rents their home to their own business for occasional meetings or retreats (14 days or fewer per year). Done correctly, the business deducts reasonable rent as an ordinary and necessary expense under sec. 162 and the owner excludes the income under sec. 280A(g). The IRS scrutinizes this arrangement between related parties. In *Sinopoli v. Commissioner*, T.C. Memo. 2023-105, the Tax Court cut claimed rent of approximately $3,000 per meeting to about $500 where the taxpayers had no comparable-rate evidence and thin proof the meetings occurred.

Minimum file documentation for clients using this strategy:

- A written rental agreement between owner and entity.

- **Fair-rental-value evidence** gathered contemporaneously — quotes for comparable meeting space (hotels, event rooms) in the same market.

- A genuine business purpose for each rental day: agenda, attendees, and minutes or notes for every meeting.

- Actual payment from the entity to the owner (not a year-end journal entry), and a day count kept safely under 15.

**Review flags:** related-party rent reasonableness; if the entity issues a Form 1099 for the rent, the exclusion still applies but expect a matching notice — report and back out the amount with an explanation rather than ignoring it.

**Sources:** IRC sec. 280A(g); IRS Pub. 527 (Residential Rental Property), "used as a home" rules; *Sinopoli v. Commissioner*, T.C. Memo. 2023-105.

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