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oil well; courts have found this legitimate profit motive to
exist in a variety of cultural contexts, see, e.g. Dwyer v.
Commissioner, T.C. Memo. 1991-123 (sponsorship expenses of NASCAR
racing were reasonable given potential prize money); Plunkett v.
Commissioner, T.C. Memo. 1984-170 (same for truck-pulling
competitions). However, the Code, like postmodern literary
theory, does not privilege any boundary between high and popular
culture--that petitioner entertained similar expectations of
ultimately achieving a large profit with his work is enough.
The seventh factor, the amount of occasional profits earned
through the activity, sec. 1.183-2(b)(4), Income Tax Regs.,
weighs heavily in favor of petitioner’s having a profit motive.
In years after 1997, he won both a fully paid sabbatical and an
additional $7,000 research grant to reward and aid his
playwriting. See Grommers v. Commissioner, T.C. Memo. 1992-343
(subsequent years relevant to section 183 analysis). While this
is not income from an activity in the usual sense of sales
revenue, it certainly is an economic benefit that petitioner
received from his playwriting.
The eighth factor is the financial status of the taxpayer.
Sec. 1.183-2(b)(8), Income Tax Regs. The regulations provide
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