123 T.C. No. 3 UNITED STATES TAX COURT JACK A. FLEISCHLI, a.k.a. JACK FORBES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5766-03. Filed July 14, 2004. In 2000, P had a net profit of more than $16,000 from the practice of law. P also earned $13,435 from acting activities and had acting-related expenses of $17,878 for 2000. A “qualified performing artist” may deduct from gross income employee business expenses related to his or her work as a performing artist if, inter alia, the individual has adjusted gross income (before deducting those business expenses) of not more than $16,000. Sec. 62(a)(2)(B), (b)(1), I.R.C. P contends that “adjusted gross income” in sec. 62(b)(1)(C), I.R.C., includes only adjusted gross income from the performance of services as a performing artist. Held: The term “adjusted gross income” in sec. 62(b)(1)(C), I.R.C., means the same as “adjusted gross income” in sec. 62(a), I.R.C., and thus is computed based on a taxpayer’s gross income from all sources.Page: 1 2 3 4 5 6 7 8 9 Next
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