James L. Christian - Page 2




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          $79 allowed by respondent for “research and development”; (2) a             
          $5,328 rent deduction claimed out of $6,660 paid for use of an              
          apartment in connection with petitioner’s writing activity; and             
          (3) of $4,369 claimed as a deduction for supplies in connection             
          with petitioner’s retreat activity, any more than the $666                  
          allowed by respondent.1  By reason of petitioner’s failure to               
          substantiate the deductions claimed, we sustain respondent’s                
          determinations.                                                             
               Section references are to the Internal Revenue Code in                 
          effect for the year in issue, and Rule references are to the Tax            
          Court Rules of Practice and Procedure.                                      
               For clarity and convenience, following a short initial                 
          background statement, the findings of fact and discussion with              
          respect to the separate issues have been combined under separate            
          headings.                                                                   
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and the accompanying exhibits are                  
          incorporated by this reference.  Petitioner resided in Hemet,               
          California, at the time he filed his petition in this case.                 




               1 It is not clear from the record whether the deduction for            
          supplies allowed by respondent was over and above the amount                
          respondent allowed as an offset to the $2,336 of gross income               
          that petitioner received from retreat participants.  This                   
          question should be resolved in the Rule 155 computation.                    




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