Jack A. Fleischli, a.k.a. Jack Forbes - Page 1

                                   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

Last modified: May 25, 2011