- 14 -
derived from the activity.2 Sec. 183(b)(2); Elliott v.
Commissioner, supra at 973.
As the result of our holding above, it is unnecessary for us
to address substantiation issues under section 274.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
2 We are uncertain whether the notice of deficiency allowed
deductions to the extent of the reported gross income. In order
to take them into account we shall enter a decision under Rule
155.
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Last modified: May 25, 2011