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disability benefits since 1992 and that Mr. Evan was a primary
caregiver during the years in issue. The record reflects that
only Mrs. Evan was engaged in any income-producing activity
during the years in issue, and that she was employed rather than
self-employed in a business of her own. As a result, we conclude
that petitioners are not entitled to deductions for the Schedule
C business expenses under section 162(a) because neither Mr. Evan
nor Mrs. Evan was in a reported trade or business, or in a
Schedule C trade or business, during the years in issue.
B. Mr. Evan’s Employment Status
On brief, petitioners argue that the Schedule C expenses
should have been reported elsewhere on their tax returns,
presumably Schedule A, because, they argue, Mr. Evan was still an
employee of Purdue University. Petitioners argue that the
reported expenses relate to Mr. Evan’s trade or business as a
professor. Petitioners base their assertion on Mr. Evan’s
possession of a Purdue University identification card, dated July
23, 2003, which states: “This is to identify George E. Evan and
to extend the same staff privileges as those available to an
employee of Purdue University.”
There is no evidence on the record that would lead us to
agree with petitioners’ assertion that Mr. Evan was employed by
Purdue University during the years in issue. The identification
card only states that Mr. Evan is entitled to the privileges
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