- 8 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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