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Schedule C Losses
Petitioner submitted a Schedule C, Profit or Loss From
Business, to respondents’s counsel for four putative businesses.
Supporting documents relating to only one of them were provided
in response to the Court’s August 4, 2005, order.
On November 1, 2000, petitioner purchased a one-third
interest in a luxury suite at Enron Field/Minute Maid Park for
Houston Astros baseball games for $26,000. The “business”, as
described by petitioner, was the resale of the luxury suite
tickets. Petitioner argues that he is entitled to claim a loss
of $17,671.54 from this “business”.
Petitioner’s evidence that he was carrying on a ticket
resale business is a receipt for purchase or use of the luxury
suite, a receipt for catering services in the suite, and one
invoice to one person for “2 Nights Enron Box” at $1,008 per
night.
Section 162(a) generally allows a deduction for ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on a trade or business. Generally, no deduction is
allowed for personal, living, or family expenses. See sec. 262.
The taxpayer must show that any claimed business expenses were
incurred primarily for business rather than social reasons. See
Rule 142(a); Walliser v. Commissioner, 72 T.C. 433, 437 (1979).
To show that the expense was not for personal reasons, the
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