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Tax Court Rules of Practice and Procedure.
Some of the facts have been stipulated and are so found.
Petitioners resided in Sunnyvale, California, when the petition
was filed. References to petitioner are to Joseph R. Trudel.
Respondent determined a deficiency of $2,100 in petitioners’
1997 Federal income tax. The issues for decision are: (1)
Whether petitioner’s writing and handyman activities during 1997
were engaged in for profit within the meaning of section 183; and
(2) whether petitioners are entitled to a deduction for self-
employed health insurance expenses under section 162(l).
Background
Petitioner has been employed as a computer programmer and
has worked in consumer affairs as an investigator of consumer
complaints at a state attorney general’s office. During the year
in issue, petitioner worked for about 6 months at Coast Personnel
Services. Petitioner has also engaged in a series of writing
activities and handyman, landscaping, and gardening activities
(handyman activities) that are the subject of this case.
Writing Activity
Petitioner became interested in writing while attending
Grossmont College in the early 1980s. He joined the staff of the
college newspaper and contributed articles as a staff writer. In
1983 petitioner founded a consumer newsletter that he named “San
Diego Scope”. The newsletter, which was published six times each
year, addressed various consumer-related issues such as rental
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