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and that the taxpayer's primary purpose for engaging in the
activity must be for income or profit."
Petitioner did not establish that he was engaged in a trade
or business during 1993 and 1994. Petitioner earned no gross
receipts from the purported activity during the 2 years at issue
and presented no documentary information to establish exactly
what type of an activity he was purportedly engaged in. He
testified he was engaged in an engineering activity but presented
no evidence as to the nature of the engineering services he
provided, the nature of his clients, the date the activity
commenced, and why, during 1993 and 1994, he had no gross income
from such an activity. Petitioner testified he had an
engineering background and had taught engineering at two or three
colleges, and, although the Court has no reason to doubt such
testimony, the Court is not satisfied that petitioner's
background established a trade or business during 1993 and 1994.
On this record, the Court holds that petitioner failed to
establish that he was engaged in a trade or business activity
during 1993 and 1994.
4. Sec. 6651(a) Failure-to-File Addition to tax
The next issue is whether petitioner is liable for the
additions to tax under section 6651(a)(1) for his failure to file
Federal income tax returns for 1993 and 1994. Section 6651(a)(1)
imposes an addition to tax for a taxpayer's failure to file
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