John K. Jorman, Jr. and Audrey Jorman - Page 8

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          considering such evidence we find that petitioners are entitled             
          to a moving expense deduction in the amount of $1,524.25.3                  
          Schedule C Deductions                                                       
               Petitioner is no doubt connected in some fashion with the              
          real estate industry, as evidenced by the licenses he holds and             
          his activities in prior years.  However, it is clear that                   
          petitioner was not engaged in any real estate business during               
          1991.  Although petitioner testified as to what he did in other             
          years, he provided no explanation whatsoever regarding what his             
          real estate activity consisted of in 1991.  The introduction of             
          checks made payable to "cash" and drawn on some "business"                  
          account tells us little, if anything, about the nature of the               
          activity.  In those instances where a check was made payable to a           
          specific payee, it appears that the transaction involved a                  
          personal rather than a business expense.                                    
               In countless opinions far too numerous to cite, including              
          one involving petitioner,4 this Court has resolved disputes                 

          3The deduction is computed as follows:  Expenses incurred                   
          for transportation of household goods ($1,247.25), plus two round           
          trips by car from Bloomington to Kokomo for househunting, at the            
          standard mileage rate provided in Rev. Proc. 90-59, 1990-2 C.B.             
          644 (2 round trips x 240 miles per trip x $.275 per mile = $132),           
          plus travel by car from Bloomington to Kokomo in connection with            
          the move (120 miles x $.275 = $33), plus total meal expenses for            
          househunting and temporary quarters ($140 x .80 = $112).                    
          4In Jorman v. Commissioner, T.C. Memo. 1994-613, we held                    
          that petitioner's real estate activity was not engaged in with an           
          actual and honest profit objective in 1990 so as to allow for               
          deductions under sec. 162(a).                                               

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