- 22 - [sic].” No other documentary evidence elaborated upon these purported sales or the status of the line in 1998. Critically, however, even if the products continued to be sold in 1998, petitioners apparently did not consider the endeavor connected to the “Automobile construction” business for which they submitted a Schedule C, in that no gross receipts were reported. They also never alleged that any of the expenditures reported on the Schedule C derived from these products. We therefore conclude that the potential existence at some point of this product line has little, if any, bearing on whether the Schedule C business was a going concern in 1998. Finally, the exhibits introduced by petitioners also contain three letters dated from August through November of 1999 regarding potential investment by third parties in Shrike Cars. These letters make no mention of any specific project and therefore cannot imply the existence of any definite and focused ongoing business. On this record, the Court can only surmise that Shrike Cars was at most in the startup phase of any automobile construction or automobile marketing venture in 1998. The evidence indicates that the expenditures reported on petitioners’ Schedule C are within the pale of section 195 costs, particularly as elucidated in legislative history. A significant portion of petitioners’ exhibits relate to proposals soliciting third-party interest, andPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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