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(2)(A). Petitioners have also failed to show that they used the
B&B exclusively for business purposes.
Further, petitioners did not substantiate the B&B expenses.
They produced no books or records substantiating, among other
things, the amount of rent collected, the number of days that
guests stayed, or the rates that guests paid. We are left with
little more than petitioners’ Schedule C, on which they listed
marginal gross income for the B&B and substantial expenses. A
schedule of expenses is not sufficient to meet petitioners’
burden, however. See Cluck v. Commissioner, 105 T.C. 324, 338
(1995) (summary schedules insufficient to entitle taxpayer to
claimed deductions). Accordingly, based upon a lack of
substantiation, a general dearth of evidence, and the personal
use of the B&B, petitioners are not entitled to deduct any of the
disputed expenses for any portion of their residence in 1997. We
therefore sustain respondent’s disallowance of the B&B expenses.
C. Writing Activity Expense
Finally, we must determine whether petitioners may deduct
expenses in 1997 and 1998 related to Mr. Lofstrom’s writing
activities. The evidence includes manuscripts that Mr. Lofstrom
allegedly drafted, including a science fiction novel called “Out
of the Mando Galaxy by Nnak Kamon” and a health and fitness book
12(...continued)
expenses not deductible where taxpayer did not rent residence at
least 15 days and personal use exceeded 14 days).
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