- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011