- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011