8 that she leased a computer which she used to organize her accounts. Petitioner introduced copies of two invoices for monthly lease payments. There is no evidence in the record that petitioner paid either of these bills. In addition, petitioner did not maintain any records of her business use of the computer as required by section 274(d). Thus, petitioner has not established that she is entitled to any deduction for the business use of the computer. Petitioner contends that she incurred an $8,000 loss in her Too Close To Home activity in 1989, and she argues that she is entitled to deduct the amount of this loss in that year. On brief respondent requests that we find the following facts: "Petitioner carried on the Too Close To Home activity from June 1989 to December 1989. She incurred an $8,000 loss with respect to this activity during the taxable year." We accept this as a concession as to the amount of the loss incurred by petitioner. Respondent argues, however, that petitioner did not engage in this activity for profit, and that she is therefore not entitled to deduct this amount. Section 162 allows deductions for ordinary and necessary expenses paid or incurred in carrying on a trade or business. Section 183 generally limits allowable deductions to the extent of gross income generated by "an activity not engaged in for profit". Sec. 183(b). Whether petitioner was engaged in the activity for profit depends on whether she undertook the activityPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011