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As we understand, the business consisted of renting
photographic and audiovisual equipment primarily for conventions.
This aspect of the Schedule C business concerned the activities
of petitioner’s former husband. The former husband was employed
by Multi-Media Unlimited, which apparently was a similar
business, and High Definition Digital, the nature of which is not
defined in the record. The former husband owned a Jeep
automobile that he used in his employment, for commuting, and in
his Schedule C activity. At trial, petitioner could not produce
any record or log as to his use of the Jeep.
The Schedule C also included a second business described as
“public data research”. This activity was conducted by
petitioner. Petitioner performed one research project in this
activity during 1998 and was not paid for that project.
The 1998 Federal income tax return was prepared by a
certified public accountant using copies and summaries of records
compiled by petitioner. Respondent disallowed the Schedule C
deductions for failure to substantiate and increased the Schedule
C income based on income of the former husband reported by third
parties on Forms 1099-MISC, Miscellaneous Income. Petitioner’s
former husband did not file a petition with this Court and,
although notified of petitioner’s claim for relief from liability
as an innocent spouse, he did not seek to intervene in these
proceedings. When petitioner and her former husband divorced the
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