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records. See sec. 1.274-5T(c)(2), Temporary Income Tax Regs., 50
Fed. Reg. 46017 (Nov. 6, 1985). Passenger automobiles are listed
property under section 280F(d)(4)(A)(i).
As discussed above, petitioner's consulting activity was not
carried on in a businesslike manner. Petitioner did not maintain
a separate business bank account, formal books, or accounts of
the activity's transactions. Instead, to substantiate his
claimed Schedule C expenses, petitioner presented this Court with
a group of receipts. Contrary to petitioner's assertions, most
of the receipts do not establish the business purpose of
petitioner's claimed expenses. However, petitioner reported
gross receipts from his consulting activity for 1996 in the
amount of $1,563. We find that in regard to the expenses claimed
that are not subject to section 274(d), there is sufficient
evidence in the record to allow deductions up to the amount of
gross receipts. Accordingly, we hold that petitioner is entitled
to deductions for Schedule C expenses in the amount of $1,563.
See sec. 183(b)(2).
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011