-23- 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.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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