Joseph R. and Diana K. Trudel - Page 10




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         preoccupation with other activities during 1997, including his 6-            
         month stint working as an independent contractor for Coast                   
         Personnel Services and his 8-week trip to the east coast.  These             
         excuses for petitioner’s failure to receive income from the                  
         handyman and landscaping activity simply are not credible.                   
              Given the relative simplicity of the activity and the fact              
         that petitioner has conducted it for several years, there is no              
         plausible explanation why petitioner’s total expenses are three              
         times his gross receipts if he was truly engaged in the activity             
         for profit.  On this record, we conclude that petitioner’s                   
         handyman activity during 1997 was not engaged in for profit                  
         within the meaning of section 183.  Consequently deductions from             
         the handyman activity are limited to the $370 income reported                
         from that activity.                                                          
         B. Writing Activity                                                          
              Petitioner’s writing activity is concerned entirely with an             
         8-week cross-country trip he took with his wife in the spring and            
         summer of 1997.  Petitioner claims that he is a professional                 
         writer, planned this trip to conduct research for a series of                
         travel articles, particularly concerning the Civil War, and kept             
         receipts and records showing his expenses of more than $12,000.              
              Petitioner is not trained as a professional writer.  Prior              
         to 1997, he had dabbled at writing by preparing film and theater             
         reviews and submitting them to local newspapers for publication.             
         He was paid $50 for each of these occasional pieces.  Petitioner             




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