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his piloting for American Eagle, as "PILOT/FLIGHT
INSTRUCTOR/ANTIQUE AIRCRAFT EXPERT/A/C DEALER". He reported
gross receipts in the amount of $3,394 and claimed the following
expenses:
Car & truck expenses $455
Legal & professional services 1,235
Rent 780
Travel 260
Dues & subscriptions 556
Books 25
Total $3,311
Respondent concedes that petitioner has substantiated all of
the claimed expenses but did not allow deductions for the car and
truck expenses, rent, travel, and dues and subscriptions.
Respondent's position is that the disallowed expenses are
nondeductible personal expenses which are not related to the
gross receipts reported on the Schedule C.
Petitioner admits that the $3,394 which he reported on the
Schedule C was received by him for commercial flying services
which he performed for a company called Hills-Gilbertson prior to
1993. He also admits that the disallowed expenses were not
related to the services he provided to Hills-Gilbertson.
The disallowed expenses were related, however, to
petitioner's involvement with an organization called Confederate
Air Force, Inc. (CAF) which is dedicated to the preservation of
World War II combat aircraft. Based on the record, we find that
his involvement with CAF during 1993 did not constitute the type
of activity that entitles him to deductions for his claimed
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