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Revenue Code in effect for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioners’ Federal
income taxes of $3,443 for 1997, $2,740 for 1998, and $3,370 for
1999. After concessions by the parties,1 the issues for decision
are: (1) Whether petitioner Carla Whitehurst’s bowling activity
constitutes an activity not engaged in for profit; (2) if the
activity was engaged in for profit, to what extent petitioners
are entitled to deduct the claimed Schedule C expenses; and (3)
whether petitioners are entitled to certain claimed itemized
deductions.2
Petitioners resided in Annapolis, Maryland, and in Bermuda
at the time they filed their petition. Some of the facts have
been stipulated and are so found. For clarity and convenience we
have combined our findings of fact and conclusions.
1 Petitioners concede that they are not entitled to a
deduction for an additional personal exemption for 1998 claimed
on their return and that they are not entitled to the deductions
claimed for Mr. Whitehurst’s work clothes and shoes for 1997,
1998, and 1999.
Respondent concedes that petitioners are entitled to
deductions for State taxes of $1,501 for 1999; union dues of $264
for 1997, $264 for 1998, and $260 for 1999; cleaning expenses of
$250 for 1997, $260 for 1998, and $270 in 1999; subscription
expenses of $100 for 1997, $250 for 1998, and $250 for 1999; job
agency expenses of $125 for 1997; and tax preparation fees of
$180 for 1997.
2 Respondent also adjusted petitioners’ additional child
tax credits for 1998 and 1999 and petitioners’ education credits
for 1998 and 1999. These adjustments are computational;
therefore, we need not address them.
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