Forrest Jackson - Page 5




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        Petitioner’s Packs to Go activity began in 1996 as a packing,                 
        shipping, and moving service.6  Petitioner had already been                   
        offering business management and consulting services.  In 2002,               
        petitioner expanded her business activity to include “business                
        prep, marketing, drawing up business plans, where to find start-up            
        money, computer services and video recording services.”  Packs to             
        Go, according to the Schedule C petitioner prepared, employed the             
        accrual method of accounting.                                                 
             Respondent disallowed all of petitioner’s claimed Schedule C             
        deductions because, according to respondent, petitioner has not               
        shown that Packs to Go was a trade or business for which                      
        petitioner is entitled to Schedule C deductions.  Continuing,                 
        respondent asserts that even if Packs to Go were an activity                  
        engaged in for profit, petitioner’s claimed expenses were not                 
        adequately substantiated.                                                     
                                    Discussion                                        
             In general, section 162(a) allows a deduction for all                    
        ordinary and necessary expenses paid or incurred during the                   
        taxable year in carrying on a trade or business.  In order for an             
        activity to be considered a trade or business for the purposes of             

             5(...continued)                                                          
          activity on Schedule C for either 2001 or 2003.                             
               6It does not appear that any registration formalities were             
          in place with respect to Packs to Go.  We infer from the record             
          that the name Packs to Go was first employed in 1996 and                    
          encompasses all services available from petitioner.                         






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