-12-
Neal Sperling, a Hollywood script agent, requesting that he
submit a plot summary of his book for consideration as a made-
for-television movie or feature film. Petitioner is presently a
member of Washington Independent Writers, The Authors Guild,
Poets and Writers, and Writers Market Book Club. During the
years in issue, petitioner spent approximately 25-35 hours per
week on his writing activity.
Apart from that activity, petitioner reported the following
income on his Federal income tax returns:
1993 1994
Wages $53,076 $54,243
Dividend income 6,111 4,847
State/local tax refund 174 999
Capital gain (loss) (3,000) (3,000)
Total 56,361 57,089
In 1993, petitioner began treating his writing activity as a
trade or business. From that year on, he began filing a Schedule
C (Profit or Loss From Business), in which he listed his princi-
pal business or profession as author. As of the date of trial,
petitioner's writing activity had not resulted in a profit for
any year, as reflected in the following table:
Year Net Loss
1993 $15,190
1994 23,517
1995 9,177
1996 8,183
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