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The Court finds that petitioner has not shown that he is
entitled to a dependency exemption deduction for Stacy Brown for
1994 or 1995.
Schedule C Activities
Petitioner provided to respondent, for the years under
consideration, Schedules C for five different activities that
petitioner claims were operated as businesses. Deductions are
allowed under section 162 for the ordinary and necessary expenses
of carrying on an activity that constitutes the taxpayer’s trade
or business. Deductions are allowed under section 212(1) and (2)
for expenses paid or incurred in connection with an activity
engaged in for the production or collection of income or for the
management, conservation, or maintenance of property held for the
production of income.
Petitioner, in order to show that he was engaged in a trade
or business, must show not only that his primary purpose for
engaging in the activity was for income or profit but also that
he engaged in the activity with “continuity and regularity”.
Commissioner v. Groetzinger, 480 U.S. 23, 35 (1987).
With respect to either section, however, the taxpayer must
demonstrate a profit objective for the activity in order to
deduct associated expenses. See Jasionowski v. Commissioner, 66
T.C. 312, 320-322 (1976); sec. 1.183-2(a), Income Tax Regs. The
profit standards applicable for section 212 are the same as those
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