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business include use of a to-be-restored fire engine for
rent or lease to movies, parties and promotions.
Petitioner’s testimony concerning the business can be summarized
as follows. During the year at issue, petitioner’s business
consisted of a rented space in an antique market. Petitioner
would open his retail space on one day each month in order to
conduct his business, but his merchandise was available at other
times for viewing and possibly sales by another merchant.
Petitioner has had no sales or other income from this business in
any year, aside from sales in 1999 which “wouldn’t have been over
$100”.
Petitioner did not present the Court with any documentary
evidence concerning either the existence of the Schedule C
business or the nature or amount of the claimed expenses. The
amounts reported on the amended return merely represent
petitioner’s assertions and are not evidence that petitioner was
engaged in any business or that he incurred any of the expenses.
The only evidence provided by petitioner concerning the Schedule
C business is his own self-serving, uncorroborated testimony,
which we do not accept as credible evidence that a bona fide
business existed or that he incurred the additional expenses.
Because petitioner has presented no substantiation of the
business or any of the expenses, we conclude that he is not
entitled to any additional deductions and that he is not entitled
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Last modified: May 25, 2011