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The parties stipulated that petitioner’s total business

expenses allowable on the consulting business Schedules C were

$42,197 for 1994, $34,114 for 1995, and $37,988 for 1996, as

Net profit

41,769

21,952

25,663

Less net profit reported on return

(17,753)

Additional profits

24,016

7,037

13,094

IV.

Business Losses a

s Real Estate Dealers

respondent determined in the notices of deficiency.

We thus hold that petitioner had additional profits from his

consulting business of $24,016 for 1994, $7,037 for 1995, and

1994

1995

1996

$83,966

$56,066

$63,651

$13,094 for 1996, computed as follows:

Gross receipts Expenses

For the years at

issue, petitioner and Mrs. Wood claimed

deductions on the prop

erty management Schedules C for expenses

(that resulted in net

losses) related to their ownership of real

property, including th

e New Jersey house, the Florida house, the

undeveloped land in Fl

orida, the Brookdale timeshare, and the

Gulfstream timeshare,

and petitioner’s management of the

apartment owned by his

mother.

In

addition,

in

1996,

they

claimed a business los

s on the sale of the Florida house.

Respondent disall

owed the net losses petitioner claimed on

the property managemen

t Schedules C ($121,966 in 1994, $72,546 in

1995, and $345,223 in

1996) because petitioner did not establish,

alternatively, (1) tha

t he and Mrs. Wood were in the property

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