Sheriel L. Sexcius - Page 10

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          entitled to deduct expenses in excess of income, thereby                    
          conceding the section 183 issue originally involved in this case,           
          she continued to claim expenses that either were not                        
          substantiated or clearly were personal nondeductible expenses.              
          She contends that this case is different than her prior cases               
          because of her concession and because respondent disallowed all             
          of her deductions in this case and thus made substantiation an              
          issue for the first time.  In T.C. Memo. 1993-310, however, the             
          Court explained the difference between the first year that                  
          petitioner litigated here, which she won, and the later years, in           
          which her manner of conducting the activity demonstrated lack of            
          profit objective.  In T.C. Memo. 1996-175, moreover, petitioner's           
          deductions were disallowed for lack of substantiation.  In that             
          opinion, we stated:                                                         
                    Petitioner failed to produce at trial any                         
               substantiating evidence with respect to the deductions                 
               she claimed on her Schedules A and C.  Given her prior                 
               experiences in this Court, she was no doubt aware that                 
               the production of such evidence was expected and                       
               necessary to support her claimed entitlement to the                    
               deductions in dispute.  We can only conclude that her                  
               failure to produce such substantiating evidence results                
               from her failure to have maintained adequate books and                 
               records as required by section 6001 and the                            
               corresponding regulation.  * * *                                       
          To the extent that petitioner is claiming deductions for personal           
          expenses, her claims are groundless.  Although we found that she            
          is entitled to some deductions, on the entire record we infer               
          that petitioner has instituted or maintained this proceeding                





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