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letter the bank sent him. The documents submitted by petitioner
in no way established the amount or amounts petitioner paid for
the shares or the amounts he originally deposited for such
shares. Petitioner contended that the stock was no more than a
savings account and that the redemption was nothing more than a
return of his money plus the 1 percent in excess of his original
deposit. However, he presented no evidence to show when such
moneys had been deposited or the amount that had been deposited.
Petitioner, therefore, failed to establish the economic outlay
necessary to claim basis. Thus, the Court finds that petitioner
had a zero basis in the 260 shares of Citizens Federal Stock that
were redeemed in 1993 and 1994. Accordingly, respondent's
determination is sustained.
3. Section 162 Trade or Business Activity
Petitioner claimed that he incurred deductible trade or
business expenses during 1993 and 1994 in connection with an
engineering business. He did not describe what type of
engineering activities he was engaged in or what kinds of
engineering services he performed, if any, during the years in
question. He admitted having no gross receipts for either year
from such an activity.
Section 162(a) provides: "There shall be allowed as a
deduction all the ordinary and necessary expenses paid or
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