- 14 - for disallowing any deductions in this case. Accordingly, we will not inquire whether petitioner's activity of showing the exotic automobiles was an activity engaged in for profit. III. Trade or Business For 1989 and 1990, respondent disallowed losses passed through from the corporation to petitioner. Respondent disallowed such losses in their entirety, in the amounts of $13,218 and $13,357, for 1989 and 1990, respectively. The corporation was an S corporation, and petitioner was entitled to take into account his pro rata share of the corporation's items of income and loss. See sec. 1366(a). One ground on which respondent disallowed the losses was that, during 1989 and 1990, the corporation was not carrying on a trade or business as required by section 162(a). Section 162(a) provides in pertinent part: "There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business". The corporation reported neither gross receipts nor gross income for either 1989 or 1990. Its ordinary losses reported on its Federal income tax returns were composed of the following items: 1989 1990 Taxes $38 $45 Interest 1,154 892 Advertising 38 100Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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