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do not evidence business engagement. Indus. Research Prods.,
Inc. v. Commissioner, 40 T.C. 578 (1963). In Evan v.
Commissioner, T.C. Memo. 2004-180, the Court disallowed
deductions claimed for Schedule C business expenses where the
only income realized was from an employment relationship and not
from a Schedule C trade or business.
The Court rejects petitioner’s argument that his salary from
the V.A. should be aggregated or attributed to his Schedule C
activities as a counterargument to respondent’s determination
that, because there was no trade or business income, the expenses
related thereto are not deductible. Petitioners cited no
authority to support this argument. Petitioner was an employee
of the V.A., and, as such, his wages or salary were subject to a
treatment different from income from or losses from a self-
employed trade or business activity. As an employee with the
V.A., he was issued Forms W-2, Wage and Tax Statement, which
reflected deductions for Social Security taxes and other
deductions that would not be applicable in a self-employed
activity. The Court, therefore, rejects that argument. An
employer-employee relationship is not a self-employment activity.
The Court finally considers whether petitioners are entitled
to deductions for job search expenses. Such expenses were
claimed by petitioner as Schedule C trade or business expenses.
However, it is obvious, as noted earlier, that, if petitioner was
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