- 22 - Petitioner's testimony was highly ambiguous with respect to both the activities of Thomason Solar and the existence of his own individual solar energy activities, if any, in 1991. Additionally, petitioner was wholly unresponsive to respondent's request for him to enlighten the Court as to his methods for differentiating between his corporate and noncorporate activities. The types of expenses that petitioner asserts are attributable to his solar energy activity in 1991 (i.e., canceled checks) fit within the parameters of the meagerly described purpose and activities of Thomason Solar. Petitioner has failed to satisfy his burden of proving that he, individually, carried on any solar energy activities in 1991 in addition to or separate from those activities conducted through Thomason Solar. He further failed to prove that any of the expenses he alleges are attributable to his solar energy activity in 1991 were not properly deductible on the corporate return of Thomason Solar. On this record, the Court is satisfied that the expenses petitioner alleges are attributable to his solar energy activity in 1991 would have been properly deductible on the corporate return of Thomason Solar, rather than on petitioners' individual return for 1991. Consequently, the Court holds that petitioners, as individuals, were not engaged in a solar activity as a trade or business during 1991.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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