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to the sale or rental of the Harwichport property. Petitioner
responded with cancelled checks payable to various newspapers,
but he produced no advertisements. The only advertisements
produced at trial were obtained by respondent. We find that the
Harwichport property was not available for rent in 1990 and that
the property was not available for sale prior to October 28,
1990. We conclude that petitioner's activity on the Harwichport
property did not constitute a trade or business in 1990.
Petitioner's level of activity and attempted disposition of the
Harwichport property indicate that petitioner prepared the
Harwichport property for resale during the year in issue. We
conclude that petitioner held the Harwichport property for the
production of income in 1990.
In general, deductions incurred for the production of income
under section 212 are subject to the same requirements and
restrictions that apply to a trade or business expense deduction
under section 162. Estate of Davis v. Commissioner, 79 T.C. 503,
507 (1982); Hubbart v. Commissioner, 4 T.C. 121, 124 (1944). In
order to be deductible, the expenditures must be ordinary and
necessary. Secs. 162(a), 212. Petitioner must prove a proximate
connection between the expenditure and the conduct of a profit-
seeking activity. Larrabee v. Commissioner, 33 T.C. 838, 841
(1960). In general, an expenditure made primarily to secure a
personal benefit is not deductible, sec. 262; whereas, a similar
expenditure may be deductible if made primarily for a profit-
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