Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent determined Federal income tax deficiencies for petitioner's 1989 and 1990 tax years in the amounts of $12,380 and $6,104, respectively. The deficiencies are attributable to respondent's disallowance of Schedule C deductions due, in part, to petitioner's failure to substantiate them and also because respondent determined that petitioner's Schedule C activity was not engaged in for profit within...
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