- 57 - C. Other Expenses As tables 3 and 4, supra, show, (1) petitioner reported Schedule C gross receipts of $1,095 for 1983, $1,000 for 1984, $13,488 for 1985, and $3,565 for 1986, and (2) at respondent's urging we have concluded that petitioner had $94,713 Schedule C gross receipts for 1982. Thus, setting aside 1984 (see supra note 16), respondent takes the position that petitioner managed to earn a total of $112,793 in his Schedule C activities without even $1 of deductible expenses. We recognize that some expenditures of a trade or business are not currently deductible for one or more of several reasons; e.g., they are to be capitalized, or they are not ordinarily incurred in such a trade or business, or some provision of law forbids the deduction. Respondent has not suggested that any such bar to deduction of otherwise-substantiated expenditures applies in the instant case. We conclude that petitioner incurred and paid something in each of the years in issue in order to earn the law practice Schedule C income with which we charge him. See 18(...continued) views of whether he was in any trade or business and therefore whether he could deduct any expenses of a trade or business might well be affected by his identification of his specific activities in any claimed trade or business and how much income he reported from that trade or business. Petitioner responded that "I would submit that we can deal with this in the briefing matter." Petitioner failed to so deal with this, and so we deem him to have conceded the question of whether he was in any trade or business other than his law practice and Hall Farms. See Sundstrand Corp. v. Commissioner, 96 T.C. 226, 344 (1991); Money v. Commissioner, 89 T.C. 46, 48 (1987).Page: Previous 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 Next
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