- 9 - 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. PetitionerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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