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Regs. While we do not believe that petitioner’s income was so
high as to make tax savings his primary objective, we recognize
that petitioner may have sought after-tax savings as a way to
subsidize his writing activity. It is obvious that petitioner
enjoyed writing, although the presence of personal enjoyment from
an activity does not, by itself, establish a lack of profit
objective. See sec. 1.183-2(b)(9), Income Tax Regs.
In sum, “The gratification derived from an occupation worth
doing, possibly beneficial to others and probably requiring long
hours or arduous labor, must still not be confused with an
intention to return a profit.” White v. Commissioner, 23 T.C.
90, 94 (1954), affd. per curiam 227 F.2d 779 (6th Cir. 1955).
Accordingly, we hold that petitioner is not entitled to
deductions under section 162(a) with respect to any of his
activities. Having held that none of petitioner’s activities is
to be treated as a trade or business apart from his employment,
we need not address the issue of whether petitioner’s expenses
were adequately substantiated.
Addition to Tax
Section 6651(a)(1) imposes an addition to tax of up to 25
percent of the underpayment for failure to file a timely Federal
income tax return unless the taxpayer shows that the failure was
due to reasonable cause and not willful neglect. United States
v. Boyle, 469 U.S. 241, 245 (1985). To prove “reasonable cause”,
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