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his testimony that he was forced to dispose of his automobiles
and some equipment because the property where he lived was
rezoned by the county. It does not appear that petitioner ever
started his activity of restoring automobiles. Startup or
preopening expenses are not deductible under either section 162
or section 212. Hardy v. Commissioner, 93 T.C. 684 (1989);
Goodwin v. Commissioner, 75 T.C. 424, 433 (1980), affd. without
published opinion 691 F.2d 490 (3d Cir. 1982); Polachek v.
Commissioner, 22 T.C. 858, 863 (1954). Deduction of such
expenses, even if substantiated, is specifically denied by
section 195(a).
Board and Room Rental
The evidence, including petitioner’s testimony, leads the
Court to conclude that petitioner did not conduct his room and
board activity primarily with the objective to make a profit.
Petitioner seems to have allowed minors and others to stay in his
mobile home on the basis of his perception of their needs and
their friendship with his son or daughter. Most of the
individuals were allowed to stay with him without paying rent or
board in any form. Petitioner’s description of his guests as
people “who had been in some sort of misfortune or down and out
with nowhere to go” strongly suggests to the Court that profit
was not the primary purpose for his room and board activity.
Petitioner is clearly a caring and generous person, but this
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