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1984,16 because (1) these expenses are corporate expenses, and (2)
petitioner has not substantiated that these expenses were ever
incurred. or paid.
Petitioner contends (1) that he is entitled to deductions for
these business losses in the amounts he claimed; (2) that any
expenses of petitioner's business activities are deductible by
petitioner, because (a) although most of these entities were
formed as corporations, they were not "perpetuated" in that
manner, (b) these business entities had their charters suspended
for nonpayment of franchise taxes, and (c) petitioner was a
"guarantor on everything"; and (3) that his failure to produce
adequate records to substantiate payment of these expenses is due
to the loss of his records by fire in 1990, and that this loss was
beyond his control. Petitioner maintains that regardless of the
fact that these business entities were formed as corporations, and
that they carried on business activities in their corporate names,
their corporate forms should be ignored. Petitioner suggests that
because certain corporate formalities were not followed, these
business entities were not corporations, and alternatively because
their corporate charters were suspended they ceased being
corporations.
16For 1984, petitioner claimed $1,000 Schedule C income and
$79,595 Schedule C expenses. Respondent disallowed only $78,595
of the 1984 Schedule C expenses. Respondent has not enlightened
us as to which $1,000 of the claimed Schedule C expenses are not
disallowed.
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