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the taxable years prior to 1988, quite aside from whether such
losses, if incurred, were allowable to petitioners for tax
purposes and may be carried forward and set off against
petitioners' income for 1988, 1989, or 1990. Petitioners'
returns, which are in evidence, simply prove that these were the
returns that were filed; they are not self-proving as to the
truth of their contents. Halle v. Commissioner, 7 T.C. 245
(1946), affd. 175 F.2d 500 (2d Cir. 1949); Caruso v.
Commissioner, T.C. Memo. 1966-190.
There is nothing else in this record, including testimony
from any witness, as to the amount and allowability as a
deduction of any loss for any taxable year prior to 1988. We
hold that petitioners have not shown that they incurred a net
operating loss in any taxable year prior to 1988 that could
properly be carried forward to any taxable year in issue. On
this issue, we must therefore uphold respondent's determination.
Issue 3. Petitioners' Schedule C Expenses
Section 162(a) generally allows a deduction for all ordinary
and necessary expenses paid or incurred during the taxable year
in carrying on any trade or business. The regulations
promulgated under section 162 clarify that only those ordinary
and necessary business expenses "directly connected with or
pertaining to the taxpayer's trade or business" may be deducted.
Sec. 1.162-1(a), Income Tax Regs. In addition, under section
262(a) no portion of the expenditures attributable to personal,
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