- 2 -
2. Held, further, Ps may not deduct expenses for
a hotel or like establishment because they used the B&B
for personal purposes for an indeterminate amount of
time, and they failed to substantiate the expenses.
Sec. 280A (c)(1), (d)(1), (f)(1)(B), (g).
3. Held, further, Ps may not deduct writing
activity expenses where they failed to show that H was
engaged in the activity of writing for profit. Secs.
162, 183; sec. 1.183-2(a), Income Tax Regs.
Steven Z. Kaplan, for petitioners.
Melissa J. Hedtke, for respondent.
OPINION
KROUPA, Judge: Respondent determined a $10,552 deficiency
in petitioners’ Federal income tax for 1997 and a $2,198
deficiency for 1998. After concessions,1 the issues for decision
are:
1. Whether petitioners may claim an alimony deduction for
$29,000 in 1997 for the transfer of a contract for deed. Because
we find the contract for deed does not constitute cash or a cash
equivalent, we hold that they may not.
1Petitioners conceded several deductions, including auto
expenses, legal expenses for Mr. Lofstrom’s divorce, real estate
appraisal expenses, closing costs, flood insurance recovery
costs, tax return preparation fees, land abstract costs,
utilities, travel expenses, and other expenses claimed on
Schedule F, Profit or Loss From Farming, and Schedule C, Profit
or Loss From Business.
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