Rick D. Lamb and Susan L. Story - Page 11

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          New York; New Hampshire; Massachusetts; and Connecticut.  These             
          trips included visits to Bozeman, Montana, where petitioner’s son           
          lived, to Missoula, Montana, where petitioner’s daughter lived,             
          and to Park City, Montana, where Mrs. Story’s three children                
          lived.  Petitioners also visited other relatives in Virginia                
          Beach, Virginia.  Despite the obvious personal nature of these              
          excursions, petitioner contends, nonetheless, that these trips              
          were principally in search of a job.  All expenses relating to              
          these trips were deducted as Schedule C trade or business                   
          expenses for the 2 years in question.                                       
               Respondent’s position is that, because petitioner realized             
          no income from his claimed activity for the 2 years at issue, he            
          was not engaged in a trade or business; therefore, none of the              
          Schedule C expenses are deductible as trade or business expense,            
          and, to the extent that any of the claimed expenses were                    
          deductible, an appropriate allowance was made for such expenses             
          as itemized deductions.  The Court further notes that none of the           
          job search expenses claimed related to a relocation of                      
          petitioner’s claimed self-employment medical/legal consultation             
          activity.  All of the job searching endeavors were directed to              
          petitioner’s employee status as a medical doctor.                           
               The Court agrees with respondent’s argument.  The law is               
          well settled that a business is a course of activities engaged in           
          for profit.  Activities that are for a purpose other than profit            






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