Herbert Donald Singer - Page 14




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          expenses.  At best, petitioner’s activity was a fanciful attempt,           
          not grounded in reality, to reach some promised land.                       
          Accordingly, we hold that petitioner did not engage in his                  
          “health, wealth and healing ministry” activity for profit within            
          the meaning of section 183 in either of the years in issue.7                
          B.  Schedule C Deductions                                                   
               Although petitioner did not report any income from his                 
          “health, wealth and healing ministry” activity in 1996, he did              
          report $1,400 from such activity in 1997.  This is relevant                 
          because even if an activity is not engaged in for profit, section           
          183(b) allows deductions to the extent of gross income.  Of                 
          course, deductions must still be substantiated.  See generally              
          secs. 162, 274; Hradesky v. Commissioner, 65 T.C. 87, 90 (1975),            
          affd. per curiam 540 F.2d 821 (5th Cir. 1976).  In this regard,             
          respondent contends that petitioner failed to substantiate any              
          deductions.                                                                 
               At trial, petitioner introduced no substantiation that would           
          satisfy the stringent recordkeeping requirements of section                 
          274(d).  See Sanford v. Commissioner, 50 T.C. 823, 827 (1968),              
          affd. per curiam 412 F.2d 201 (2d Cir. 1969); sec. 1.274-5T(a),             
          Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).              


               7  Our holding also serves to absolve petitioner from                  
          liability for self-employment tax for 1997, see sec. 1402(a) and            
          (c), and to deny him any deduction under sec. 164(f) for that               
          year.                                                                       





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