Dudley Joseph and Myrna Dupuy Callahan - Page 12

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          holding that the writing and supposedly related activities in               
          such case were not conducted for profit.  Petitioner did not                
          carry on her activity in a businesslike manner.  Refunding and              
          rebating, and entering sweepstakes, have long been hobbies that             
          petitioner enjoys.  She recorded her methodologies in 1982 at the           
          suggestion of a friend and with the intention of helping her                
          friends save money on groceries.  Neither manual was published              
          for 10 years until petitioner "self-published" them at an area              
          copy shop.  It was not until then, after the taxable years in               
          issue, that petitioner pursued financial assistance, wrote a few            
          published authors, and sought publicity for herself.  The record            
          does not disclose how much time, if any, petitioner spent on her            
          writing activity during the taxable years at issue, 1989, 1990,             
          and 1991.  On their 1989 and 1991 Schedules C petitioners                   
          reported gross receipts of zero; for 1990 they reported $134 in             
          gross receipts, all of which was from prizes and awards.                    
          Moreover, there was no showing that petitioners ever made a net             
          profit from petitioner's writing activity.  Respondent is                   
          sustained on this issue.                                                    
          2.   Casualty Losses                                                        
               Petitioners claimed casualty losses on their 1989 and 1990             
          returns in the respective amounts of $13,233 and $13,835.  They             
          attributed these losses to damages sustained from Tropical Storm            
          Allison and termite infestation.  Petitioners were unable to                
          apportion the total damages between Tropical Storm Allison and              




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