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1984). In addition, under section 280A(c)(1)(A), deductions
arising from the use of a dwelling unit that was used by the
taxpayer as a residence are generally disallowed unless the
taxpayer proves a portion of the dwelling unit was used
exclusively and regularly as his principal place of business or
satisfies another of the exceptions in section 280A(c).
On April 22, 2003, petitioner was served with a pretrial
order. Before the trial, petitioner did not cooperate in
informal discovery by providing respondent with any documentary
or written evidence to substantiate his claimed expenses and did
not identify any potential witnesses. In addition, petitioner
made no effort to keep respondent informed of his current address
and telephone number. Petitioner did not sign a stipulation of
facts until the day of trial. The stipulation of facts did not
address any of the substantiation issues for petitioner’s claimed
Schedule C expenses.
During the trial, petitioner presented a July 14, 1999,
Chicago Tribune newspaper article that discussed petitioner’s
background and motivational speeches as an evidentiary
submission. Petitioner presented no admissible documentary
evidence to substantiate any of the claimed expenses and gave
vague and general testimony.
As to section 274 expenses, petitioner testified that he
could recall car payments of approximately $450 per month.
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