Kathleen J. Kelly - Page 8

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            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 activity                         




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