- 15 -
accordance with section 183. It follows, and we hold, that
respondent's determination in this regard is sustained. In view
of the foregoing, we need not consider whether the provisions of
section 274(h) prohibit petitioners from deducting the expenses
related to the cruise.
In closing we note that our conclusion in this case is
limited to the years before us. Sec. 1.183-2(a) and (b), Income
Tax Regs. We also note that petitioner considers herself a
professional writer and is rightfully proud of her various
publication credits. To the extent that petitioner is paid for
the articles accepted for publication, her characterization of
herself as a professional writer is appropriate, and nothing in
this opinion should be interpreted as suggesting otherwise. Our
focus upon petitioner's writing activity as a trade or business
has been in the context of Federal income taxation and should be
so limited.
Based on the foregoing,
Decision will be
entered for respondent.
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