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petitioner's automobile repair activity during that year.
Accordingly, we sustain respondent's determination in the notice
that for 1993 petitioners are not entitled to deduct the net loss
that they claimed in their 1993 Schedule C with respect to
petitioner's automobile repair activity, and we reject petition-
ers' contention that they are entitled to deduct the net loss
that they claimed in their 1993 amended Schedule C.5
Petitioners' Claimed Section 1231 Loss
Petitioners contend that they are entitled to an ordinary
loss deduction under section 1231 for 1993 for the loss that they
realized on the sale of petitioner's Ferrari. Respondent con-
tends that petitioners are not entitled to that deduction because
they have failed to show that they used that automobile in
connection with a trade or business.
Pursuant to section 1231(a)(1), if the section 1231 gain
exceeds the section 1231 loss, that gain and loss are treated as
long-term capital gain and loss, respectively. Pursuant to
section 1231(a)(2), if the section 1231 loss exceeds the section
5 Petitioners offered into evidence a document entitled "Profit
Intent Test - The Nine Factors". In that document, petitioners
allege certain facts relating to petitioner and his automobile
repair activity that are not established by the record in this
case. We have not relied on that self-serving document as
evidence in support of any of the facts that are alleged in that
document and that are not otherwise supported by the record in
this case.
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