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anything.2 See Bendetovitch v. Commissioner, T.C. Memo. 1993-
443.
As evidence of his sales efforts, petitioner provided
numerous testimonial type letters to petitioner regarding Micron
Systems. However, none relate to the year 1995.3
Furthermore, focusing on each deduction provides no
meaningful insight into the nature of petitioner’s activities
during 1995. At trial, petitioners conceded that they were not
entitled to some of the deductions. Some of the deductions not
conceded could not be explained; others relate to expenses that
would have otherwise been incurred regardless of the activity.
We understand that 10 years prior to the year in issue,
petitioner obtained a patent on the auxiliary oil filtration
system for internal combustion engines. We think it likely that
petitioner intended to make a profit from it someday. However,
petitioners failed to explain, and we cannot devine, what
petitioner was doing in 1995 that would entitle them to the
2 We cannot determine the source of the gross receipts
reported on the Schedule C.
3 One letter dated March 31, 1999, addressed to petitioner
at his home address is prepared on letterhead of Compuware,
Oakland, California, and signed by Robbin Everson, one of the
petitioners in this case. The subject of this letter is
petitioners’ 1993 Pontiac Grand Am. Another letter was written
by a service manager of SuperShuttle in 1991. Petitioner
discontinued his relationship with SuperShuttle in 1994.
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