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called “A Common Sense Approach to Weight Loss, Nutrition,
Physical Fitness, and Exercise for the Non-Fanatic of All Ages.”
We accord little weight to these submissions, however, because
respondent did not have the opportunity to cross-examine
Mr. Lofstrom at trial. Respondent argues nonetheless that, even
considering these manuscripts, petitioners have not shown that
Mr. Lofstrom engaged in his writing activities for profit. We
agree.
Taxpayers may deduct ordinary and necessary expenses paid or
incurred during the taxable year in carrying on any trade or
business. See sec. 162. To do so, taxpayers must demonstrate
that they were involved in the activity on a continuous and
regular basis and that their purpose for engaging in the activity
was for income or profit. See Commissioner v. Groetzinger, 480
U.S. 23, 35 (1987); Wittstruck v. Commissioner, 645 F.2d 618, 619
(8th Cir. 1981), affg. T.C. Memo. 1980-62; Jasionowski v.
Commissioner, 66 T.C. 312, 320-322 (1976); Gentile v.
Commissioner, 65 T.C. 1, 4 (1975); sec. 1.183-2(a), Income Tax
Regs. Whether the required profit objective exists is determined
on the basis of all the facts and circumstances of each case.
See Hirsch v. Commissioner, 315 F.2d 731, 737 (9th Cir. 1963),
affg. T.C. Memo. 1961-256; Golanty v. Commissioner, 72 T.C. 411,
426 (1979), affd. without published opinion 647 F.2d 170 (9th
Cir. 1981); sec. 1.183-2(a), Income Tax Regs. While a reasonable
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