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which are not deductible under section 262. As to the
documentation that represented business expenses, petitioner
failed to establish that the receipts that related to deductible
expenses were not already allowed in the notices of deficiency by
respondent. Consequently, for the years 1993 and 1994, the Court
sustains respondent on the disallowed Schedule A and Schedule C
expenses.
Petitioner’s critical care nursing activity for 1995 and
1996 needs to be considered separately for the following reason.
The parties stipulated that petitioner earned “only W-2 wages”
during 1995 and 1996, which implicitly suggests that petitioner
did not earn any income in her self-employed critical care
nursing activity during these 2 years. In the notices of
deficiency, respondent did not allow or concede any deductions
for trade or business expenses for this activity for 1995 and
1996. Nonetheless, in spite of the stipulation referred to,
petitioner reported gross receipts of $4,684 and $8,173,
respectively, for 1995 and 1996, on Schedule C of her returns for
those years in connection with her critical care nursing
activity. In the notices of deficiency, these income amounts
were not removed, and all of the claimed expenses were
disallowed. The Court concludes that the stipulation of the
parties on this issue is in error, since petitioner did earn
gross income during 1995 and 1996 from her critical care nursing
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