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"otherwise allowable" under section 183(b)(1). Because
petitioner reported no gross income from her Mary Kay activity
for 1996 and 1997, she is not entitled to any deductions under
section 183(b)(2) for those years.
For 1998 petitioner reported gross income of $438, and her
deductions for that year are limited to that amount. Id.
Respondent, however, determined that petitioner did not
substantiate any of her expenses for the year, and petitioner
produced no such evidence at trial. Petitioner is therefore not
entitled to any deductions for her Mary Kay activity for 1998.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011