8
log, rent expense for the entire year was calculated as 40
percent of $11,400. Petitioner testified that this figure
corresponded to his mortgage payments for the year. Petitioner
offered no support for this percentage. Further, petitioner
testified that he did not move his shop until the end of March
1990; thus, this allocation of his annual mortgage payments would
be inconsistent. Petitioner also testified that he paid two
women to work at his shop and that their salaries were included
in shop expenses. However, the expense log does not list any
payees supporting petitioner's testimony.
We believe that petitioner incurred some expense in carrying
on his jewelry design activity during the years in issue.
However, on this record, we are unable to determine or estimate
the amount of such expense. Accordingly, petitioner has not
established that he is entitled to the deductions claimed.
Because petitioner has not shown he is entitled any
deductions in connection with his jewelry design activity for the
years in issue, we need not address the issue of whether
petitioner was engaged in such activity for profit.
To reflect the foregoing,
Decision will be entered
for respondent.
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