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suggested an alternative method to compute those gross receipts.
We find reasonable respondent’s method of reconstructing
petitioner’s December 1995 gross receipts.
We conclude that petitioner had unreported gross receipts in
the amount determined by respondent for 1994. Petitioner’s
unreported gross receipts for 1995 are adjusted to account for
respondent’s concessions for 1995 and for reasons stated above at
paragraph C-1.
D. Miscellaneous Business Deductions
Petitioner deducted car and truck, commission, rent,
utilities, and wage expenses for 1994 and 1995.
1. Whether Petitioner Was Engaged in a Trade or Business
Other Than the Tax Preparation Business
Petitioner deducted various expenses on his Schedules C for
1994 and 1995 for his tax preparation business, the so-called
one-room schoolhouse, and for his lobbying activity.
Petitioner testified that in 1993 he started lobbying for
several groups, such as the Citizens Against Government Waste and
the Gun Owners of America, but it did not generate any income in
1993. He also said he earned $200 per year lobbying for the Gun
Owners of America in 1994 and 1995. He also claimed he used the
Lower Wetumpka Road house for a rebreeding activity, but he did
not describe what the activity was.
Petitioner did not establish that the one-room schoolhouse,
the lobbying activity, or the rebreeding activity was an activity
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