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did not have an “employer” with respect to his book writing
project. It is for this reason that petitioner amended his 2003
return to recharacterize these expenses as “profit/loss from a
separate business activity.”
Petitioner has not convinced us that his book writing
project is a separate activity rather than an outgrowth of his
university teaching and research. While it may be true, as
petitioner suggests, that university professors generally are not
required to write books, it does not follow that a university
professor who writes a book is engaged in a separate business
activity. Petitioner’s book is in the same academic discipline
as the one petitioner teaches at the university. Petitioner’s
contract with Cambridge University Press clearly identifies
petitioner as a university professor. Petitioner based his book,
at least in part, on teaching notes he had developed over the
years, and he used the book in teaching courses at the
university. We find that petitioner’s book writing project is so
interconnected with his university teaching and research as to
not constitute an activity separate from that of his occupation
as a university professor. See Topping v. Commissioner, T.C.
Memo. 2007-92.
A taxpayer may have only one principal place of business for
each business activity in which he is engaged. Curphey v.
Commissioner, 73 T.C. 766, 775-776 (1980). Where a taxpayer’s
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