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After concessions, the issues for decision are: (1) Whether
petitioner conducted his photography-related activity during 1993
and 1994 with the intent to make a profit within the meaning of
section 183, and (2) whether petitioner is entitled to deduct
$8,291 in unreimbursed employee expenses for taxable year 1995.
All section references are to the Internal Revenue Code as
in effect for the years in issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
The parties have stipulated some of the facts, which we
incorporate in our findings by this reference. When he
petitioned the Court, petitioner resided in Whitefish Bay,
Wisconsin.
Since the mid-1970s, petitioner has been employed full time
as a computer and accounting consultant. Since 1982, he has been
employed in this capacity by Compuware Corp. (Compuware) or its
predecessor in interest. Over the years, petitioner has
developed a keen interest and expertise in photography, becoming
a member of numerous professional photography organizations.
In 1982, petitioner formed JJT, Ltd. (JJT), a sole
proprietorship that he operated out of his home, without any
employees. Petitioner formed JJT to provide support services to
Professional Services, Inc. (PSI), a corporation that was in the
business of selling foundry supplies and sand-blasting equipment.
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