St. Elmo H. Nauman, Jr. - Page 7

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                                       OPINION                                        
               Section 162(a) allows a deduction for all ordinary and                 
          necessary expenses paid or incurred during the taxable year in              
          carrying on any trade or business.  To be engaged in a trade or             
          business within the meaning of section 162, “the taxpayer must be           
          involved in the activity with continuity and regularity and * * *           
          the taxpayer’s primary purpose for engaging in the activity must            
          be for income or profit.”  Commissioner v. Groetzinger, 480 U.S.            
          23, 35 (1987).                                                              
               Petitioner asserts that, during 1993, he was engaged in the            
          trade or business of writing on the topics of religion and                  
          philosophy, of working towards creating a homeless shelter,                 
          and/or of being a lecturer/teacher.  Respondent asserts that                
          petitioner was not engaged in any such business activities during           
          1993 except as an employee, and that he was writing for “mere               
          personal enjoyment”.  We agree with respondent.                             
               With respect to petitioner’s lecturing/teaching activities,            
          the only remuneration received by him was Form W-2 wage income              
          from the INS, Chapman University, and the Navy.  We find that               
          petitioner did not perform teaching or lecturing activity                   
          separate and apart from this employment.  Clearly, petitioner is            
          not entitled to Schedule C deductions for expenses relating to              
          wage income.  It is possible that petitioner is entitled to a               
          Schedule A employee business expense deduction for overnight                





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