Jane Anne Jeffries - Page 5




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          when I could be working with people who could afford to pay for             
          my services.”  She further stated:  “I intended to have a                   
          business called Conversation With Connection.  It will be when I            
          retire from the school district.”  Petitioner is not retired from           
          the school district.                                                        
               Petitioner deducted on her Schedule C expenses which were              
          personal expenses not deductible under section 262.  She deducted           
          moneys paid to a handyman to paint her house.  She deducted                 
          moneys paid for a carpet delivered to her house.  She deducted a            
          gift (a membership in the Screen Actor’s Guild) to a friend’s               
          daughter.  She deducted payments to a person who repaired her               
          personal automobile.  She deducted payments for assistance during           
          a funeral.  Thus, petitioner’s use of her Schedule C allowed her            
          to claim deductions for many nondeductible personal expenses.               
               Section 183(a) disallows any deductions attributable to                
          activities not engaged in for profit except as provided under               
          section 183(b).  A taxpayer need not have a reasonable                      
          expectation of profit.  However, the facts and circumstances must           
          demonstrate that he or she entered into the activity, or                    
          continued the activity, with the actual and honest objective of             
          making a profit.  Taube v. Commissioner, 88 T.C. 464, 478 (1987);           
          Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd. without             
          opinion 702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income             
          Tax Regs.  The taxpayer's objective to make a profit must be                





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