N. Joseph Calarco - Page 16

                                   - 15 -                                             
               the books I've bought that aren’t television                           
               criticism: they've still informed my criticism of                      
               the television. ...  Oh!--and the chair I sit in,                      
               of course: very important what your posture is when                    
               you criticize a television.  And the food I eat--                      
               which literally makes up the cells that form the                       
               critic of the television....                                           
          Kornbluth, supra.                                                           
               Petitioner has fallen victim--at least at times--to this               
          fever, claiming many quotidian activities, such as reading                  
          newspapers and renting movies, to be “business-related”.  He is,            
          at some level of abstraction, no doubt correct.  But we must                
          administer the tax laws as they are.  Having decided that                   
          petitioner intended to profit from his playwriting, we must sift            
          through the specific deductions that he claims so as to determine           
          their allowability.                                                         
               Petitioner’s Schedule C deductions fall into fifteen                   
          categories, named as follows on the 1997 return:20 (1) mileage;             
          (2) automobile depreciation; (3) interest; (4) legal and                    
          professional services; (5) supplies; (6) travel; (7) books,                 
          recordings, and video; (8) “business cellular;” (9) Internet;               
          (10) software; (11) “tickets to various performances, viewing;”             
          (12) “the business portion of phone expense (70 percent);”                  
          (13) “miscellaneous from cash (ATM);” (14) periodicals; and                 



               20  Unfortunately, the categories in petitioner’s posttrial            
          submission do not match the categories on the return.  We discuss           
          the categories as they appear on the return.                                





Page:  Previous  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  Next

Last modified: May 25, 2011