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scholars of both ancient civilizations9 and modern authors.10
This case follows in that long, but little-noted,
tradition. Petitioner, N. Joseph Calarco, is a respected
professor of theater at Wayne State University in Detroit. He
also writes plays. On his 1997 tax return, he deducted his
playwriting expenses as a Schedule C business loss. Respondent
disallowed both the loss and several itemized deductions that
petitioner took on his Schedule A. These disallowances created a
deficiency of $3,869 to which respondent added an accuracy-
related penalty of $774. Petitioner, following the lead of Henry
VIII’s first Queen Katherine,11 filed a timely petition in this
Court.
Act I. Background
Petitioner has at least four times filed petitions
contesting respondent’s disallowance of deductions that he
claimed. The issues before the Court for those years were mostly
whether specific deductions were allowable. In this case,
9 See, e.g., Tonia Sharlach, “Provincial Taxation and the Ur
III State” (2004).
10 See A. L. Rowse, “William Shakespeare, A Biography” 280-
281 (1963) (use of obscure records to trace author’s movements);
Vitale v. Commissioner, T.C. Memo. 1999-131 (use of obscene
records to trace author’s movements).
11 “These exactions, whereof my sovereign would have note,
they are most pestilent to the bearing; and, to bear’ em the back
is sacrifice to the load.” “Henry VIII”, I. ii. 11. 47-50.
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