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Petitioner’s 1989 and 1990 Schedules C report that she has
an unincorporated business that provides acting, modeling, and
art/design services. The 1989 Schedule C reports income of $650
and cost of goods sold and deductions totaling $13,800; i.e.,
cost of goods sold ($6,700), advertising ($1,800), legal and
professional services ($1,500), office expense ($2,000), supplies
($1,200), and utilities ($600). Petitioner’s 1990 Schedule C
reports income of $750 and cost of goods sold and deductions
totaling $15,200; i.e., cost of goods sold ($4,000), advertising
($2,700), legal and professional services ($2,200), office
expense ($4,500), supplies ($1,200), and utilities ($600).
Respondent disallowed all of the costs of goods sold and
deductions reported on petitioner’s 1989 and 1990 Schedules C.
In part, respondent determined, petitioner did not prove that any
of these amounts were: (1) Paid or (2) ordinary and necessary
business expenses.
Petitioner must prove respondent's determination wrong.
Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).
Petitioner has not done so. She has produced no meaningful
evidence rebutting respondent's determination, and the record is
devoid of evidence otherwise disproving it. Petitioner claims
she had the documents necessary to disprove respondent’s
determination, but that the documents were either lost by her or
destroyed in a hurricane. We find this argument unpersuasive.
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