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The parties stipulated that petitioner’s total business
expenses allowable on the consulting business Schedules C were
$42,197 for 1994, $34,114 for 1995, and $37,988 for 1996, as
respondent determined in the notices of deficiency.
We thus hold that petitioner had additional profits from his
consulting business of $24,016 for 1994, $7,037 for 1995, and
$13,094 for 1996, computed as follows:
1994 1995 1996
Gross receipts $83,966 $56,066 $63,651
Expenses
Net profit 41,769 21,952 25,663
Less net profit reported on return (17,753)
Additional profits 24,016 7,037 13,094
IV. Business Losses as Real Estate Dealers
For the years at issue, petitioner and Mrs. Wood claimed
deductions on the property management Schedules C for expenses
(that resulted in net losses) related to their ownership of real
property, including the New Jersey house, the Florida house, the
undeveloped land in Florida, the Brookdale timeshare, and the
Gulfstream timeshare, and petitioner’s management of the
apartment owned by his mother. In addition, in 1996, they
claimed a business loss on the sale of the Florida house.
Respondent disallowed the net losses petitioner claimed on
the property management Schedules C ($121,966 in 1994, $72,546 in
1995, and $345,223 in 1996) because petitioner did not establish,
alternatively, (1) that he and Mrs. Wood were in the property
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