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summaries, we cannot in most instances determine which expenses
relate to the military memorabilia activity,8 are personal
expenses, or are truly business expenses. Except as noted above,
petitioner has produced insufficient evidence to persuade us that
respondent's disallowance of the deductions reported in Schedules
C of the returns is in error. Consequently, with the exceptions
noted above, we uphold respondent's disallowance of deductions.
Based on the foregoing, we find that the net profit from
petitioner's consulting business was $336,231.66 in 1990,
$356,394.00 in 1991, and $443,172.00 in 1992.9
8We are unable to determine the exact magnitude of
petitioner's military memorabilia activity, but it appears to be
quite extensive. During the examination, petitioner or his agent
provided a document in the form of a ledger. The ledger appears
to show six transactions in 1990 for amounts of $46,836, $4,400,
$27,755, $8,084, $64,874, and $20,100 that relate to petitioner's
military memorabilia activity.
9The net profit was calculated as follows:
1990 1991 1992
Reported receipts $176,389.00 $187,427.00 $172,078.00
Unreported receipts 216,143.00 208,134.00 272,902.00
(continued...)
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