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to turn customers away based on their inability to pay. She did
not maintain a separate bank account for depositing whatever
payments she did receive. With respect to the expenses claimed,
petitioner did not attempt to introduce into evidence any books
or records, or source documents, that reflected the nature and
amounts of such expenses.
Petitioner reported income and deductions from her tutoring
and counseling activity on a Schedule C for every year from 1979
through 1991. As noted above, in each year since 1979 for which
there is evidence in the record, petitioner claimed a substantial
loss from her activity. The losses incurred from year to year
from petitioner's tutoring activity were apparently financed from
her other earnings.
In 1989, petitioner reported on Schedule C gross receipts of
$4,399 and deductions in the amount of $14,312, resulting in a
$9,913 loss. Respondent disallowed the deductions claimed on
petitioner's Schedule C for 1989 on the grounds that her activity
was not engaged in for profit and that she failed to substantiate
any of the deductions claimed.
Petitioner also claimed $20,124 in itemized deductions on
her Schedule A for the year 1989, including $14,534 in
miscellaneous deductions attributable to employee business and
other expenses. Respondent disallowed the miscellaneous
deductions claimed for lack of substantiation.
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