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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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