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holding that the writing and supposedly related activities in
such case were not conducted for profit. Petitioner did not
carry on her activity in a businesslike manner. Refunding and
rebating, and entering sweepstakes, have long been hobbies that
petitioner enjoys. She recorded her methodologies in 1982 at the
suggestion of a friend and with the intention of helping her
friends save money on groceries. Neither manual was published
for 10 years until petitioner "self-published" them at an area
copy shop. It was not until then, after the taxable years in
issue, that petitioner pursued financial assistance, wrote a few
published authors, and sought publicity for herself. The record
does not disclose how much time, if any, petitioner spent on her
writing activity during the taxable years at issue, 1989, 1990,
and 1991. On their 1989 and 1991 Schedules C petitioners
reported gross receipts of zero; for 1990 they reported $134 in
gross receipts, all of which was from prizes and awards.
Moreover, there was no showing that petitioners ever made a net
profit from petitioner's writing activity. Respondent is
sustained on this issue.
2. Casualty Losses
Petitioners claimed casualty losses on their 1989 and 1990
returns in the respective amounts of $13,233 and $13,835. They
attributed these losses to damages sustained from Tropical Storm
Allison and termite infestation. Petitioners were unable to
apportion the total damages between Tropical Storm Allison and
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