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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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Last modified: May 25, 2011