- 20 - publication of his work. There is no history of profit potential nor any projections of profit potential from his activity. Accordingly, we conclude that petitioner did not engage in his research and writing activities with the primary purpose of producing income apart from the salary he earned as a professor or apart from the fellowship he received. Therefore, petitioner's activities do not constitute a separate trade or business, and the related expenses are not deductible on Schedule C. We also disagree with respondent's determination that petitioner incurred the expenses in question in his capacity as an employee of UConn. Rather, we conclude that petitioner incurred the expenses in relation to the fellowship income. It is clear from this record that the expenses claimed relate to the research and writing which petitioner engaged in pursuant to the fellowship. Since we have held that the fellowship income constitutes noncompensatory income, petitioner's fellowship expenses are deductible pursuant to section 212. 2. Rental of Petitioners' Connecticut House We now address respondent's determination with respect to the items of income and expense attributable to the rental use of petitioners' house. Respondent, employing the limitations set forth in section 183, determined that petitioners did not engage in the activityPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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