Earl L. Miller and Nancy B. Miller - Page 15

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            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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