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.
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