Jack A. Fleischli, a.k.a. Jack Forbes - Page 3

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               Petitioner was a self-employed practicing attorney in 2000.            
          He earned a net profit of more than $16,000 from the practice of            
          law in 2000.                                                                
               Petitioner also worked as an actor in 2000.  He used the               
          professional name “Jack Forbes”.  In that year, he earned $13,435           
          from acting and had acting-related expenses of $17,878.  He                 
          reported a net loss from acting on a Schedule C, Profit or Loss             
          From Business, attached to his 2000 return.                                 
               During an examination of petitioner’s 1999 return,                     
          respondent allowed petitioner to treat his acting expenses as               
          adjustments to gross income for 1999.                                       
               Respondent determined that petitioner had adjusted gross               
          income of more than $16,000 in 2000 and that, as a result,                  
          petitioner may not deduct his acting expenses of $17,878 as                 
          adjustments to gross income under section 62(a)(1) and (2)(B).3             
                                       OPINION                                        
          A.   Whether Adjusted Gross Income in Section 62(b)(1)(C)                   
               Includes Only Income From the Performance of Services as a             
               Performing Artist                                                      
               1.   Background                                                        
               In computing adjusted gross income, a qualified performing             
          artist may deduct from gross income employee business expenses              
          incurred in connection with his or her performance of services in           


               3 Respondent concedes that these expenses are unreimbursed             
          employee expenses for 2000.                                                 





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