Wanat v. Comr., T.C. Sum. Op. 2012-92

(case involved deductibility of business deductions for personal “businesses” run by airline pilot; plaintiff was sole proprietor of dog bed manufacturing company from 2000-2002; from 2002-2004, plaintiff purchased several undeveloped parcels of land; plaintiff traveled to these properties throughout time period but had little development or rental activity on any property; court allowed deductions in 2002 for business expenses for dog bed manufacturing except vehicle or depreciation expenses due to lack of substantiation and allocation between personal and business use; expenses were disallowed for “real property business” in 2003 and 2004 under I.R.C. §162 because activities in acquiring unimproved parcels did not constitute trade or business; under I.R.C. §212, however, court allowed deductions for advertising, interest, and utilities; plaintiff not entitled to depreciation on any properties or other deductions due to failure to establish expense related to real estate activity, lack of substantiation on amount, expense capital in nature, or expenses actually related to acquisition of personal vehicle).