- 9 - Petitioner claims that she conducted her Packs to Go activity from an apartment in a subsidized low-income housing development known as the Dulles Center Apartments. She claims she did not live there, an assertion that respondent disputes. Petitioner’s apartment was furnished with dishes, plants, a sofa, a loveseat, two tables, and a coffee table. Petitioner’s lease agreement provided that “the use of the premises for any purpose other than as a private dwelling solely for the use of the Resident” was not permitted. The lease made no mention of petitioner’s Packs to Go activity. Moreover, for the first year of the lease (from December of 1999 to December of 2000), petitioner’s nephew was a signatory to the lease. Without deciding whether petitioner did or did not live at the Dulles Center Apartments, and even if we were to accept petitioner’s uncorroborated assertions that she conducted her Packs to Go activity from a low-income apartment unit in violation of her lease agreement, we believe that such a highly unusual arrangement is inconsistent with conducting a commercial enterprise in a businesslike manner. Petitioner did not keep reliable books and records for her Packs to Go activity. Only one signed contract between petitioner and a putative client was introduced into evidence. The receipts that petitioner produced in support of her claims for various business deductions were inconsistent with or contradictory of herPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: March 27, 2008