Alvin S. Kanofsky - Page 1

                                 T.C. Memo. 2006-79                                   

                               UNITED STATES TAX COURT                                

                          ALVIN S. KANOFSKY, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12547-04.            Filed April 18, 2006.                  

                    P, a full-time professor of physics at Lehigh                     
               University, filed 1996-2000 individual income tax                      
               returns in which he reported, on Schedule C, Profit or                 
               Loss From Business, zero gross receipts and substantial                
               deductions from alleged business activities.  R denied                 
               the 1996-98 Schedule C deductions on the ground that P                 
               was not engaged in any trade or business, and he denied                
               a portion of the 1999 and 2000 Schedule C deductions on                
               the ground that the disallowed expenses were unrelated                 
               to P’s business activities.  For all of the audit                      
               years, however, R allowed some of P’s expenses as                      
               deductions on Schedule A, Itemized Deductions.  For                    
               1997, R also determined that P is subject to the sec.                  
               6662, I.R.C., accuracy-related penalty.                                
                    1.  Held:  R’s denial of business expense                         
               deductions under sec. 162(a), I.R.C., sustained.                       

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