- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: March 27, 2008