- 19 - each such year to or for the use of that organization within the meaning of section 170(c). Accordingly, we sustain respondent's determinations disallowing the charitable contributions that petitioner claims for those years. Claimed Schedule C Deductions With Respect to TFC Engineering Petitioner claims on brief (1) that TFC Engineering was engaged during 1990 and 1991 in the business of purchasing, repairing, and reselling automobiles and (2) that that alleged business generated losses during those years of $6,246 and $7,562, respectively.13 Respondent disputes petitioner's claims.14 To support his position with respect to the claimed Schedule C losses for TFC Engineering, petitioner relies on certain docu- mentary and testimonial evidence. The documentary evidence con- 13 Although petitioner reported no income in his 1990 Schedule C with respect to TFC Engineering, he is claiming herein that he did have income for 1990 attributable thereto. Although peti- tioner deducted certain expenses in his 1990 Schedule C with respect to TFC Engineering, he is claiming herein that he in- curred different types and amounts of expenses during 1990 with respect thereto. In addition, although petitioner did not in- clude a Schedule C for TFC Engineering in his return for 1991, he is claiming herein Schedule C gross income and expenses with respect thereto for that year. 14 Respondent also contends that, because the claimed auto- mobile-related activity of TFC Engineering was not an activity engaged in for profit during 1990 and 1991, pursuant to sec. 183, petitioner is not entitled to deduct any expenses in excess of income. Petitioner does not address respondent's contention under sec. 183. On the record before us, we find that petitioner has failed to establish that the automobile-related activity in which he claims TFC Engineering engaged during 1990 and 1991 is an activity engaged in for profit within the meaning of sec. 183.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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