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of section 183;1 and if so, (3) whether petitioners have
substantiated the ordinary and necessary expenses claimed with
respect to the writing activity.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioners resided in Simi Valley, California.
For all years in issue, petitioners filed with their joint
returns Schedules C, Profit or Loss From Business, for
petitioner’s activities. On the Schedules C, petitioner listed
his principal business or profession as writing, investing, job
shopping, art, engineering, science, consulting, teaching,
photography, and research. All of the expenses listed on the
Schedules C were only with regard to petitioner’s writing
activity, and this is the only activity in which petitioner
engaged with any regularity. Therefore, we consider the
Schedules C as pertaining only to petitioner’s writing activity.
For convenience, we combine the findings of fact and opinion for
each issue.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. All amounts have been rounded to the nearest dollar
for convenience.
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Last modified: May 25, 2011