George R. and Donelle C. Hawthorne - Page 7




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          he conducted under the name Hawthorne Enterprises, Mr. Hawthorne             
          deposited $1,000 every other month into a checking account in the            
          name of Hawthorne Enterprises.                                               
               Petitioners claimed in Schedules C of their returns for                 
          1992, 1993, and 1994 expenses that Mr. Hawthorne incurred under              
          the name Hawthorne Enterprises totaling $13,337.59, $13,098.76,              
          and $9,981.94, respectively.  Included in the expenses claimed in            
          Schedule C for 1992 were $716.32 for "Legal and professional                 
          services", $2,775.04 for "Taxes and licenses", and $3,106.06 for             
          "Depreciation".  Included in the expenses claimed in Schedules C             
          for 1993 and 1994 were $3,621.18 and $2,064.25, respectively, for            
          "Taxes and licenses" and $3,106.06 for "Depreciation".                       
               In Schedules E of their 1992, 1993, and 1994 returns,                   
          petitioners reported rental income and various expenses with                 
          respect to certain real properties listed in those schedules,                
          including $549.32 claimed in Schedule E of their 1992 return for             
          "Legal and other professional fees" with respect to property                 
          identified as "315 Princeton S E, Albq".                                     
          Notices of Deficiency                                                        
               In the notice of deficiency (notice) issued to petitioners              
          for 1992, respondent, inter alia, disallowed all of the expenses             
          that petitioners claimed in Schedule C of their return for that              
          year because respondent determined that those expenses were not              
          incurred in the operation of a trade or business.  However,                  
          respondent allowed petitioners to include those disallowed                   
          Schedule C expenses as Schedule A deductions subject to appropri-            


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