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Petitioner teaches golf 3 days a week. When he is not teaching,
and on his days off, petitioner practices and plays golf.
On Schedule C, Profit or Loss from Business, filed with his
1991 Federal income tax return, petitioner reported the income
and expenses of his golfing activity. He reported gross income
of zero and $16,384 expenses. After 1991, petitioner did not
file a Schedule C for his golfing activity. Petitioner's
explanation for not filing Schedule C's for his golfing activity
after 1991 is as follows: "I had no [wage or Schedule C] income,
so how could I write off my expenses against no income?"
Petitioner has kept no formal books or records. He did keep a
sheet titled "Tax Info" that listed his golfing expenses for
1991, but the amount of the expenses claimed on Schedule C does
not correspond with the amounts listed on the sheet. Petitioner
also kept certain receipts for expenditures relating to his
golfing activity.
In the notice of deficiency, respondent determined that
petitioner was not engaged in his golfing activity for profit
within the meaning of section 183 and disallowed the loss for
1991. In the alternative, respondent determined that, if
petitioner was engaged in his golfing activity for profit, then
the expenses incurred by petitioner constitute start-up costs
under section 195.
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