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entitled to deduct expenses in excess of income, thereby
conceding the section 183 issue originally involved in this case,
she continued to claim expenses that either were not
substantiated or clearly were personal nondeductible expenses.
She contends that this case is different than her prior cases
because of her concession and because respondent disallowed all
of her deductions in this case and thus made substantiation an
issue for the first time. In T.C. Memo. 1993-310, however, the
Court explained the difference between the first year that
petitioner litigated here, which she won, and the later years, in
which her manner of conducting the activity demonstrated lack of
profit objective. In T.C. Memo. 1996-175, moreover, petitioner's
deductions were disallowed for lack of substantiation. In that
opinion, we stated:
Petitioner failed to produce at trial any
substantiating evidence with respect to the deductions
she claimed on her Schedules A and C. Given her prior
experiences in this Court, she was no doubt aware that
the production of such evidence was expected and
necessary to support her claimed entitlement to the
deductions in dispute. We can only conclude that her
failure to produce such substantiating evidence results
from her failure to have maintained adequate books and
records as required by section 6001 and the
corresponding regulation. * * *
To the extent that petitioner is claiming deductions for personal
expenses, her claims are groundless. Although we found that she
is entitled to some deductions, on the entire record we infer
that petitioner has instituted or maintained this proceeding
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