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habeas corpus proceedings of incarcerated clients. Obviously, he
did not see these clients at home, and petitioner received no
fees for this activity during the 2 years at issue. There is no
evidence that petitioner was involved in a habeas corpus
proceeding during the 2 years at issue.
Petitioners considered these two described activities as a
trade or business for Federal income tax purposes. His claimed
office was in his home.
For 1999 and 2000, petitioners filed joint Federal income
tax returns, each of which included a Schedule C, Profit or Loss
from Business. On Schedule C for 1999, petitioners reported zero
gross income, expenses of $50,312, and a net loss of $50,312. On
the 2000 Schedule C, petitioners reported negative gross income
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