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Telephone 123
Total 22,939
Petitioner received a bachelor of arts degree with a major
in optical engineering and a minor in mathematics. Petitioner
does not have a license to trade securities; he has not taken any
formal education in the trading of securities.
Respondent determined that petitioner's consulting activity
was not an activity engaged in for profit. In the alternative,
respondent determined that petitioner's claimed Schedule C
expenses were personal expenses and not ordinary and necessary
business expenses.
Section 183 provides that if an activity engaged in by an
individual is not engaged in for profit, no deduction
attributable to such activity shall be allowed, except as
provided in section 183(b). In the case of an activity not
engaged in for profit, section 183(b)(1) allows a deduction for
expenses that are otherwise deductible without regard to whether
the activity is engaged in for profit. Section 183(b)(2) allows
a deduction for expenses that would be deductible only if the
activity were engaged in for profit, but only to the extent that
the total gross income derived from the activity exceeds the
deductions allowed by section 183(b)(1).
An "activity not engaged in for profit" is any activity for
which deductions would not be allowed under section 162 or under
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Last modified: May 25, 2011