Jane Anne Jeffries - Page 7




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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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