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Other than the Schedule C, prepared over 4 years after the
period in question, petitioner offered no documentary evidence to
corroborate his testimony that the claimed expenses were paid.
Petitioner offered no testimony that would connect several of the
expense categories, such as bad debts, commissions and fees,
depreciation and section 179 expense, and meals and
entertainment, to the research activities he claimed were being
undertaken and which provided the rationale for claiming expense
treatment on the Schedule C. On this record, we conclude that
petitioner has failed to substantiate that the claimed expenses
were paid or incurred.
In addition, petitioner offered no evidence beyond his self-
serving testimony that these expenses were paid "in carrying on"
a trade or business within the meaning of section 162(a).
Petitioner reported no gross receipts on the Schedule C and
offered no documentary evidence whatsoever of the conduct of a
business. Petitioner testified that he did not have plans to
start a specific business when he arrived in Hong Kong, and given
that the parties have stipulated that his arrival occurred in
November 1990, the available evidence suggests that it was
unlikely that petitioner was actually engaged "in carrying on any
trade or business" for purposes of section 162(a) within the 1990
taxable year. Cf. Commissioner v. Groetzinger, 480 U.S. 23, 35
(1987). On this record, we conclude that petitioner has failed
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