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after she retired. There is no credible evidence that she spent
time on this activity. Petitioner has a history of substantial
losses, with no prospect for any gain. Petitioner deducted
personal expenses nondeductible under section 262 on her Schedule
C. Upon a review of the facts in the record, we conclude that
petitioner did not engage in the CWC activity with an actual and
honest objective of making a profit, and that under section 183
she is not entitled to claim the deductions in issue.
Respondent’s determination is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011