- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011