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resulting in net losses. Based upon this record, we do not find
petitioner’s 1990 and 1991 Federal income tax returns convincing
evidence that petitioner’s import/export activity constituted an
active trade or business.
Petitioner has convinced us that he wanted to enter the
import/export business during the years in issue. He had at
least one plan, and he tried to get a start. But his own
evidence convinces us that he never bought, manufactured, or sold
a product or otherwise was able to get his plan into operation.
We hold that petitioners are not entitled to claimed
deductions for Schedule C expenses for 1992 and 1993.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011