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THE AUGUSTA RULE DOCUMENTATION SYSTEM Section 280A(g), Up to Tax Court Standards

THE AUGUSTA RULE DOCUMENTATION SYSTEM Section 280A(g), Up to Tax Court Standards

Almost every tax provision does one of three things. It defers income, it reduces income, or it shelters income behind an offsetting expense. Section 280A(g) does something else entirely. It removes the income from your return altogether.

Rent your home to your business for fourteen days or fewer in a tax year, at a defensible rate, for a real business purpose, and two things happen at once. The business deducts the rent as an ordinary business expense. You receive that rent and never report a dollar of it. The same money leaves the business as a deduction and arrives in your hands untaxed.

The provision earned its nickname from Augusta, Georgia, where residents rent their homes to spectators during the Masters tournament each spring. Congress added the exception in 1976 so that renting for a single tournament week would not drag a homeowner into full rental property reporting for the remaining fifty one weeks of the year. The nickname is regional. The statute is national, and a homeowner in any state may use it.

THE TWO HALVES ANSWER TO TWO DIFFERENT MASTERS

This is the point almost every article about the Augusta Rule misses, and it decides whether your position survives.

Section 280A(g) governs whether you exclude the income. Section 162(a), which allows a deduction for the ordinary and necessary expenses of carrying on a trade or business, governs whether the business deducts the payment. Those are two separate statutes with two separate tests, and a revenue agent may accept one half of your transaction and reject the other.

Section 280A is also a disallowance statute, which means its default posture is to deny deductions rather than to grant them. Subsection (a) states the general rule, being that no deduction is allowed for a dwelling unit used as a residence. Subsection (g) is the exception, and an exception carved out of a denial is read narrowly by everyone who reads it.

THE SIX CONDITIONS

Every successful position satisfies all six at once. Miss one and the strategy does not shrink. It collapses.

The property is a dwelling unit you use as a residence. A primary home qualifies automatically because you live there. A second home qualifies where your personal use exceeds the greater of fourteen days or ten percent of the days it is rented at fair value. A property held purely as a rental does not qualify, because it is not a residence.

The property is rented for fourteen days or fewer during the tax year. The statute is written as fewer than fifteen days, which means fourteen is the ceiling. The count runs per dwelling unit and per tax year, and a personal weekend rental of the same home consumes the same allowance.

The renter is a separate taxpayer from the homeowner. A person cannot contract with himself or herself, and this single condition disqualifies more owners than any other.

The rent is fair market value for comparable space in your market. A rate you invented is not a rate you can defend.

The payment and the business purpose are documented as the event happens rather than assembled afterward.

WHAT THE TAX COURT HAS ALREADY DECIDED

Two cases govern how this is examined, and the Playbook works through both.

In Sinopoli versus Commissioner, decided in 2023, S corporation shareholders deducted rent paid to themselves for the use of their homes. The court accepted that Section 280A(g) can apply and then cut the deduction to a fraction of what was claimed, because the rates ran far above what comparable local meeting space actually rented for and the meetings were inadequately documented. Jadhav versus Commissioner, decided the same year, is the second case the Playbook examines.

Read the outcome carefully. The strategy survived in both. The paperwork did not. That is the whole lesson, and it is why this package is a documentation system rather than a strategy article.

TWELVE WAYS OWNERS LOSE THIS DEDUCTION

Operating as a sole proprietorship or a disregarded single member limited liability company, so no separate taxpayer exists to pay the rent. Renting for fifteen days or more and losing the exclusion for every day of the year. Setting the rent by intuition or by copying a figure from a marketing article rather than from dated market comparables. Pricing a four hour meeting at a full week lodging rate. Paying an identical amount on an identical day each month, which resembles a distribution of profit. Holding the meeting and never producing an agenda, minutes, or an attendance record. Convening only family members with no business agenda and no business outcome. Paying in currency or by an untraceable transfer, leaving no proof of payment. Skipping the written rental agreement because the parties are the same people. Failing to authorize the rental through the governing body of the business. Forgetting that a personal weekend rental of the same home consumes the same fourteen day allowance. Deducting homeowner expenses against the excluded rent, which Section 280A(g) expressly forbids.

Each one of those has cost a real taxpayer real money.

WHAT YOU RECEIVE

A Playbook, a working spreadsheet, eleven fillable forms, and a calendar file the spreadsheet generates for you.

THE PLAYBOOK

Eight parts, twenty five numbered sections, and every line of the table of contents is a link that jumps to its page.

Part One states the law. What the rule is, where it lives in the Internal Revenue Code, the six conditions, which business entities may use it and which may not, how to count the fourteen days, how to establish and document fair market rent, how to prove the business purpose, what the homeowner gives up in exchange, payment mechanics and timing, the Form 1099 question, what the Tax Court has already decided, the nine document audit file, and the twelve failures listed above. Every rule names the page on the Internal Revenue Service website that supports it, together with the date that page was verified.

Part Two teaches the workbook. Setting it up for your tax year, the fourteen day tracker, completing an event tab block by block through all six blocks, how the numbers reach your tax return, and the year end close out procedure.

Part Three supplies nine complete one day event programs, each one a real business meeting with a real purpose. Annual strategic planning session. Quarterly governance meeting. Annual financial review and tax planning session. Annual insurance, risk, and contingency review. Standard operating procedure documentation day. Marketing and brand positioning workshop. Client advisory and referral partner roundtable. Compliance, records, and corporate formalities audit. Technology, data security, and systems review.

Part Four covers the calendar reminder system, including the five reminders attached to every event and how to install the file.

Part Five is the event document kit, presenting all eleven templates.

Part Six is where the work disappears. Nine ready to use event packs, one for each program, each carrying a written announcement to participants and a full agenda for that program. Choose a meeting, print the pack, hold the meeting.

Part Seven covers filing, storage, the naming convention, what your accountant receives and when, and how long you keep it. Retention runs seven years from the filing date of the return that claimed the deduction, because the assessment period runs three years and stretches to six where a substantial understatement is alleged.

Part Eight carries the appendices, being every authority with its source page and verification date, and a glossary.

THE EVENT PLANNING WORKBOOK

Twenty seven tabs. This is the working file, and it calculates rather than merely records.

The START HERE tab holds your setup block, and you enter each value once because every other tab reads from it. HOW TO USE and TAB BY TAB explain the system. QUICK REFERENCE and MEETING CONTENT GUIDE keep the rules beside the work. IRS SOURCES AND LINKS carries the authorities. FILING AND STORAGE states where each record goes.

Five full EVENT tabs and nine DAY EVENT tabs cover your calendar year, with two CUSTOM EVENT tabs for anything the programs do not anticipate. The FMV COMPARABLE LOG builds your rate evidence before you pay rather than after. The AUDIT FILE INDEX proves at a glance that a set is complete. The CALENDAR GENERATOR produces a file that places every deadline on your own calendar in five steps. PICK LISTS drives the dropdowns.

The fourteen day tracker reads compliant or does not, across every event you schedule, before you commit to a single date.

Every tab is protected so a calculated cell cannot be overwritten by accident. Every blue entry cell and every dropdown stays fully editable. No password is set, so nothing is locked away from you. A printable reference copy of the whole workbook ships alongside it for reading on paper or handing the structure to your accountant.

THE ELEVEN FORMS

Fillable PDFs you type into directly and save. Three are prepared once each year. Seven are prepared for each individual event. One is the cover sheet that proves the set is complete.

Meeting announcement and invitation. Meeting agenda master form. Attendance and sign in sheet. Event cost ledger. Minutes and business outcome summary. Residential meeting space rental agreement. Written consent of the governing body authorizing the rental program. Rent invoice and payment record. Fair market rent comparable log and rate selection memorandum. Event folder cover sheet and document index. Professional review record.

WHO THIS IS FOR

Business owners who own or rent the home they live in and whose business is a corporation, a partnership, or a limited liability company treated as a separate taxpayer.

WHO THIS IS NOT FOR

Sole proprietors with no separate business entity, and single member limited liability companies treated as disregarded entities. In both cases the law treats the business and the owner as the same taxpayer, and a person cannot rent a house to himself or herself. If that describes you, take this page to your accountant and ask about your entity choice before you spend anything here.

WHAT THIS PACKAGE DOES NOT DO

It does not appraise your property, gather your comparable evidence, or set or approve any rental rate. The fair market rate you use, and the evidence supporting it, are yours to establish and yours to defend. It does not assess whether your entity qualifies, and you must confirm your classification with your own certified public accountant or enrolled agent before you act. Every instrument is a blank form rather than an executed document, drafted for illustration rather than for the law of your state, and an attorney licensed in your state should review your version before you sign the first one. Oakhaven Bedrock Investments, Inc. is not a law firm, a certified public accounting firm, or an enrolled agent practice, and nothing here is legal advice or tax advice. No tax result is promised.

First Edition, Tax Year 2026. Authority verified August 11, 2026.

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