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Petitioners reported income and claimed deductions for
expenses with respect to the bowling activity as follows:
1997 1998 1999
Income:
Prize winnings $3,052 $2,725 $889
Expenses:
Car and truck1 5,889 6,240 6,258
Repairs and maintenance 703 605 542
Supplies 350 157 226
Travel 3,540 3,998 3,137
Meals and entertainment 1,271 1,295 1,034
Other (entry fees) 8,700 7,968 7,415
Total expenses: 20,453 20,263 18,612
Loss (17,401) (17,538) (17,723)
1 Petitioners claimed deductions for the standard1
mileage rate for the years at issue.
In the notice of deficiency respondent disallowed the
claimed Schedule C deductions for 1997, 1998, and 1999 and
determined that Mrs. Whitehurst did not engage in the bowling
activity for a profit. Respondent asserts that the element of
personal pleasure is inherently present in the bowling activity.
As an alternative position in the notice of deficiency
respondent disallowed the following claimed deductions:
1997 1998 1999
Car and truck $2,532 $763 $894
Supplies 350 157 226
Repairs and maintenance 703 605 542
Travel 2,220 3,332 2,610
Meals and entertainment 825 977 629
Other (entry fees) 5,483 4,562 6,246
Respondent disallowed the claimed deductions because either
petitioners did not provide books and records reflecting the
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