- 6 - 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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011