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and receipts that petitioner could explain relate to expenses
paid or incurred in connection with his rental real estate
activities, which expenses appear to have been deducted on the
Schedule E. Furthermore, certain invoices, bills, statements,
and receipts seem to involve personal, nondeductible expenses.
See sec. 262(a).
We see no connection between the Schedule C deductions here
in dispute and the records offered by petitioner to substantiate
those deductions. Furthermore, we find nothing in those records
that supports petitioner’s suggestion at trial that he is
entitled to deductions not claimed on his return. Respondent’s
disallowance of all of the deductions claimed on the Schedule C
is sustained.
2. “Carry Forward Loss” Credit/Net Operating Loss
Petitioner claimed a $138,555.16 credit for a “carry forward
loss”. At trial, petitioner attempted to explain how he computed
this amount, but we are unable to follow his explanation.7 Our
7 On brief petitioner acknowledged, properly so, that his
prior reliance on sec. 39 as support for the credit was
misplaced.
Sec. 172 allows a deduction for a net operating loss (NOL),
which may be carried back to years preceding the year of the loss
and carried over to years following the year of the loss. Sec.
172(b). The item here in dispute is described as a “carry
forward loss credit”. If petitioner intended, albeit inartfully,
to deduct an NOL carryover, the deduction would have to be denied
because he failed to establish that: (1) He sustained an NOL
prior to 1993; and (2) any portion of the NOL was available to
carry over into 1993. The copies of petitioner’s Federal income
(continued...)
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