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unable or unwilling to pay strongly suggests the absence of the
requisite profit objective necessary to support the deductions
claimed. Based upon an examination of all the facts and
circumstances, we are unable to conclude that petitioner
conducted her tutoring activity with a bona fide, honest, and
objective profit motive. Furthermore, she has failed to
substantiate any of the claimed deductions. Consequently, we
sustain respondent's disallowance of the deductions claimed on
petitioner's Schedule C for the year 1989.4
Schedule A Deductions
Petitioner reported on her Schedule A, Itemized Deductions,
deductions for employee business expenses and other miscellaneous
deductions in the amount of $14,534 for the year 1989. As
previously noted, deductions are a matter of legislative grace
and petitioner must prove her entitlement to these deductions.
Rule 142(a); New Colonial Ice Co. v. Helvering, 292 U.S. at 440;
Welch v. Helvering, 290 U.S. at 115.
Petitioner has failed to substantiate any of the deductions
claimed on her Schedule A for the year 1989. Accordingly, we
sustain respondent's determination with respect to this issue.
4Our finding with respect to petitioner's profit motive also
precludes allowing the disputed Schedule C deductions under sec.
212. Petitioner's failure to substantiate such deductions
precludes the allowance of any which might otherwise be permitted
by sec. 183.
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