- 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.
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