Elmer J. Hopson - Page 7

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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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