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provided no substantiation. At trial, petitioner offered no
substantiation for any of the deductions. Petitioner did not
have any books, records, receipts, or other documents to
substantiate expenses claimed on his Schedule C. Petitioner also
candidly admitted that “We didn’t build anything in 1999" and
that we were “unable to raise the money to do business.”
Petitioner acknowledged that he did not maintain a separate
bank account to pay expenses. He did not maintain a business
office. He operated out of his own apartment. He had no
business records, no books, no checks, and no receipts. When
asked about these, he replied “No I did not keep them.”
We conclude that petitioner did not prove that the claimed
deductions were his ordinary and necessary business expenses. We
further conclude that petitioner failed to substantiate any
Schedule C expenses claimed as deductions in 1999. For these
reasons, the Schedule C expenses are disallowed in full.
Contentions we have not addressed are irrelevant, moot, or
without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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