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or business until 1993, the tax years in issue mark the initial
stages of his activity. A significant amount of petitioner's
total deductions for 1993 and 1994 were travel expenses, which he
incurred to collect material for his books. Now that such
material has been amassed and incorporated in the manuscripts,
petitioner, as a published author, expects his writing activity
to be profitable. To remedy the unforeseeable circumstance of
his publisher's going bankrupt, petitioner has demonstrated that
he has ideas and plans for future publications which would enable
him to recoup not only his expenses, but also to make a profit.
See Golanty v. Commissioner, 72 T.C. 411, 427 (1979) ("The goal
must be to realize a profit on the entire operation, which
presupposes * * * sufficient net earnings to recoup the losses"
(quoting Bessenyey v. Commissioner, 45 T.C. 261, 274 (1965),
affd. 379 F.2d 252 (2d Cir. 1967))), affd. without published
opinion 647 F.2d 170 (9th Cir. 1981).
Second, these losses should be viewed in the context of the
nature of petitioner's activity. Works of fiction are difficult
to write and to market. We are persuaded by petitioner's state-
ment that first-time authors are not normally offered cash
advances.14 It is not surprising then, that, for the first 2
years of his writing activity, petitioner sustained losses. This
14Advances are payments to an author before publication.
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