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[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, and
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