T.C. Memo. 2006-79
UNITED STATES TAX COURT
ALVIN S. KANOFSKY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12547-04. Filed April 18, 2006.
P, a full-time professor of physics at Lehigh
University, filed 1996-2000 individual income tax
returns in which he reported, on Schedule C, Profit or
Loss From Business, zero gross receipts and substantial
deductions from alleged business activities. R denied
the 1996-98 Schedule C deductions on the ground that P
was not engaged in any trade or business, and he denied
a portion of the 1999 and 2000 Schedule C deductions on
the ground that the disallowed expenses were unrelated
to P’s business activities. For all of the audit
years, however, R allowed some of P’s expenses as
deductions on Schedule A, Itemized Deductions. For
1997, R also determined that P is subject to the sec.
6662, I.R.C., accuracy-related penalty.
1. Held: R’s denial of business expense
deductions under sec. 162(a), I.R.C., sustained.
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