Sherburne M. Edmondson, Jr. and Diane L. Edmondson - Page 7

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          attached to the return, one listing petitioner as the proprietor of         
          Glass Onion Records ("Businesswoman, Retail Sales, Marketing"), and         
          the other listing Mr. Edmondson as proprietor of S.M.E. Contracting         
          Co.4 ("General Contractor"). On the Schedule C relating to Glass            
          Onion Records, $18,188.01 of expenses was claimed; among other              
          things, the expenses were with respect to:  Debts of Glass Onion            
          Records prior to its failure; a 1988 trip to Mexico; and                    
          petitioner's education. On the Schedule C relating to S.M.E.                
          Contracting Co., $19,406.13 of expenses was claimed; among other            
          things, the expenses were with respect to renovations to the Floyd          
          Avenue house.                                                               
               Attached to the Edmondsons' 1988 return was a Form 2119 (Sale          
          of  Principal  Residence), wherein $30,948.64 of gain from the sale         
          of Mr. Edmondson's Seattle house was deferred.                              
          Notice of Deficiency and Amended Answer                                     
               Respondent disallowed all deductions claimed on the two                
          Schedules C on the basis that the Edmondsons failed to establish            
          that the expenses were deductible under section 162(a).  In the             
          amended answer, respondent asserted that the deferral of the                
          $30,948.64 gain from the sale of Mr. Edmondson's Seattle house was          
          erroneous.                                                                  




               4    Except for the 1988 tax return, there is no evidence in           
          the record with regard to S.M.E. Contracting Co.                            




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