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petitioner’s providing photographic and other services to PSI,
his taking steps to build up his own reputation and expertise in
the field of photography, his marketing of his own prints, his
production of photography exhibitions, and his future plans to
expand into such areas as the teaching of photography. We also
find it significant that in his books and records petitioner has
treated the various undertakings as one activity.
In sum, on the basis of all the evidence in the record, we
conclude and hold that petitioner had a good faith expectation of
profit from his Schedule C activity during the years in issue.
Accordingly, petitioner is entitled to the Schedule C deductions
in issue, the parties having stipulated that the amounts claimed
are adequately substantiated.
Unreimbursed Employee Business Expenses
On Schedule A, Itemized Deductions (Schedule A), of his 1995
Federal income tax return, petitioner claimed deductions for
“unreimbursed employee expenses” of $8,291, comprising $7,529 of
claimed automobile mileage expenses and $762 of claimed expenses
described on the Schedule A only as “other”. Respondent has
disallowed the $8,291 claimed deduction on the ground that it is
inadequately substantiated.6 On brief, petitioner argues only
6 The parties have stipulated that petitioner is entitled to
specified amounts of “unreimbursed employee expenses” and “car
and truck expenses” that he claimed for taxable years 1993 and
1994.
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