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analyzed separately for purposes of section 183. See Abbene v.
Commissioner, T.C. Memo. 1998-330; sec. 1.183-1(d)(1), Income Tax
Regs.
A. Handyman Activity
Petitioner began the handyman activity in 1993 or 1994.
With respect to this activity during 1997, petitioners reported
on their Schedule C gross income of $370 and total expenses of
approximately $1,100. On Schedule C petitioner did not allocate
his expenses between the handyman activity and the writing
activity. Nevertheless the record indicates that expenses for
supplies ($146), advertising ($184), business license ($20),
building materials ($118), and repairs and maintenance ($455) may
properly be allocated to the handyman activity.
Petitioners’ summary of expenses indicates that 592 miles
were driven in connection with the handyman activity.
Consequently, expenses of $186 (592 multiplied by $0.315) were
attributable to automobile mileage expenses of the handyman
activity. The automobile mileage expenses of this activity
amounted to more than half of petitioner’s gross receipts from
this activity.
At trial, when questioned as to why the gross receipts of
his handyman activity, including landscaping and gardening
services, were only $370 for the entire year, petitioner replied
“That’s just the seasonal nature of the business.” Petitioner
also attributed the modest amount of gross receipts to his
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