- 13 -
Petitioner did not seek expert advice on how to start or
maintain a business as a fiction writer or as a writer of
political commentary or about guns. Petitioner did not consult
with anyone on the economics of conducting a writing activity.
While petitioner had writing skills, they were in the technical
field of engineering and science. Although his articles about
guns were rather technical, petitioner did not have a background
on gun testing. Petitioner did not join any literary
organizations to learn more about the industry. Petitioner did
attend a writing conference “early on”, but he did not find it
helpful.
3. Time and Effort Expended
The fact that the taxpayer devotes much of his or her
personal time and effort to carrying on an activity, particularly
if the activity does not have substantial personal or
recreational aspects, may indicate a profit objective. See sec.
1.183-2(b)(3), Income Tax Regs.
We do not question the amount of time petitioner expended in
carrying on the writing activity. Suffice it to say that he
devoted a great deal of time researching, testing, and writing
about the topics that interested him.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011