Bruce Selig and Elaine Selig - Page 14

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          for disallowing any deductions in this case.  Accordingly, we               
          will not inquire whether petitioner's activity of showing the               
          exotic automobiles was an activity engaged in for profit.                   
          III.  Trade or Business                                                     
               For 1989 and 1990, respondent disallowed losses passed                 
          through from the corporation to petitioner.  Respondent                     
          disallowed such losses in their entirety, in the amounts of                 
          $13,218 and $13,357, for 1989 and 1990, respectively.  The                  
          corporation was an S corporation, and petitioner was entitled to            
          take into account his pro rata share of the corporation's items             
          of income and loss.  See sec. 1366(a).  One ground on which                 
          respondent disallowed the losses was that, during 1989 and 1990,            
          the corporation was not carrying on a trade or business as                  
          required by section 162(a).                                                 
               Section 162(a) provides in pertinent part:  "There shall be            
          allowed as a deduction all the ordinary and necessary expenses              
          paid or incurred during the taxable year in carrying on any trade           
          or business".                                                               
               The corporation reported neither gross receipts nor gross              
          income for either 1989 or 1990.  Its ordinary losses reported on            
          its Federal income tax returns were composed of the following               
          items:                                                                      
                                   1989                       1990                    
                    Taxes          $38                 $45                            
                    Interest       1,154                    892                       
                    Advertising    38                       100                       




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