James P. Shea and Patricia H. Shea - Page 13




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          $743,561 from a business described as “international                        
          transportation - aircraft” composed of the following:                       
                    Advertising                        $106                           
                    Legal and professional service     11,662                         
                    Office expense                     112                            
                    Travel                             80,883                         
                    Meals and entertainment (less 20                                  
                         percent)                      436                            
                    Other direct cost of sales         650,000                        
                    Investment research                320                            
                    Misc.                              27                             
                    Bank charges                       15                             
                    Net loss                           $743,561                       
               Petitioners Christopher and Kim Shea also filed a joint                
          Federal income tax return for 1992.  On a Schedule C to that                
          return, Christopher reported negative gross income of $150,000              
          from a business described as “international transportation”,                
          consisting solely of cost of goods sold in that amount.                     
               In notices of deficiency, respondent determined that                   
          petitioners had not shown that their Schedule C activity was a              
          trade or business and disallowed their respective losses.                   
          Petitioners filed timely petitions contesting respondent’s                  
          determination and alleging, in the alternative, that the Schedule           
          C losses were deductible under section 165, 166, or 1244.                   
                                       OPINION                                        
               Petitioners contend that they are entitled to deduct the               
          losses claimed on their respective Schedules C because they were            
          engaged in the trade or business of “international                          






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