-15-
Schedules C for the years in issue because "it has not been shown
that * * * [petitioner] either started a trade or business or
entered into an activity for profit. * * * [Nor has he] estab-
lished that any amount was for an ordinary and necessary business
expense".
OPINION
Section 162(a) generally allows a deduction for all ordinary
and necessary business 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).
We are satisfied that petitioner's writing activity was
conducted with continuity and regularity during the years in
issue. Nevertheless, in order for an activity to be considered a
trade or business within the meaning of section 162, a taxpayer
must conduct the activity with the requisite profit motive or
intent. See id.
Petitioner argues that he engaged in his writing activity
with the intent to make a profit and that his Schedule C expenses
for tax years 1993 and 1994 were ordinary and necessary to his
endeavor as an author. Respondent does not dispute that amounts
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