Broadrick R. Moore and Dawn J. Ingram - Page 15




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          derived from the activity.2  Sec. 183(b)(2); Elliott v.                     
          Commissioner, supra at 973.                                                 
               As the result of our holding above, it is unnecessary for us           
          to address substantiation issues under section 274.                         
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          























               2  We are uncertain whether the notice of deficiency allowed           
          deductions to the extent of the reported gross income.  In order            
          to take them into account we shall enter a decision under Rule              
          155.                                                                        





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