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evidence to support his claim, we are not convinced that
petitioner's business expenses equaled or exceeded income during
the years in issue. Nor are we convinced that the self-
employment income reported on the information returns represents
the total gross receipts of petitioner's business for each year.3
Petitioner asserts that he earned no income during the years
in issue because all income from his business was earned and
reported by Lorenzo Thomas. Petitioner testified that a back
injury prevented him from doing any of the actual tile setting
during the three years in issue. Therefore, petitioner asserts,
Lorenzo Thomas performed all the tile setting and earned all the
income from the business.
Petitioner did not offer medical records or any other
evidence to corroborate his claim that a back injury prevented
him from working during the years in issue. We also note that
during the audit of petitioner's returns he did not mention that
he had a back injury and did not assert that Lorenzo Thomas
earned all the income from the business. We hold that petitioner
has failed to show that he had business expenses that equaled his
income during the years in issue.
Petitioner also contends that he did not make the personal
expenditures attributed to him by respondent during the years in
3Section 6041(a) requires a payor to issue a Form 1099-MISC
to a nonemployee payee (as well as to respondent) regarding
remuneration for services only when such remuneration equals or
exceeds $600 in any taxable year.
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