4
On the Schedules C attached to his 1988 and 1989 Federal
income tax returns, petitioner claimed the following deductions
with respect to his brokerage activities:
Expense 1988 1989
Advertising $114 $83
Bank service charges 10 9
Car and truck expenses 1,440 1,009
Depreciation 4,190 3,088
Dues and publication 81 -0-
Freight -0- 606
Insurance 42 -0-
Legal and professional fees 153 287
Office expenses 99 271
Supplies 45 269
Travel 62 222
Meals 96 145
Utilities 138 -0-
"Biof Project" 196 -0-
"R & D Tools" -0- 600
"Elect. Resc." -0- 62
"ANW Srvcs." -0- 135
Postage -0- 59
Total 6,666 6,845
Petitioner reported no income during 1988 and 1989 other than the
wages he earned as an engineer for the School Board.
Respondent determined that petitioner did not engage in
brokerage activities for profit and therefore disallowed all of
the deductions claimed attributable thereto. Alternatively,
respondent determined that petitioner failed to substantiate the
deductions and to prove that the expenditures were ordinary and
necessary to any business that he conducted.
As a preliminary matter, petitioner argues that the U.S. Tax
Court is unconstitutional because it unfairly shifts the burden
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