- 4 - of expenses petitioners incurred while on a trip to Europe in 2001 and of research expenses, all related to the proposed WWI book. In support of his claimed deductions, Mr. Deward provided a letter from a publisher, Military History Press L.L.C., dated August 15, 2005, saying that they would like to review his materials “with an eye to future publications”. Mr. Deward also provided a document titled “The Development of Military Doctrine by the German and British Armies During the Course of the Great War” which he presented to his local chapter of the “Great War Society” in September 2006. Discussion Section 162(a) generally allows a deduction for all ordinary and necessary expenses paid or incurred during the taxable year in carrying on a trade or business. What constitutes a trade or business is not statutorily defined; rather, it requires an examination of the facts in each case. Commissioner v. Groetzinger, 480 U.S. 23, 36 (1987). To be engaged in a trade or business, the taxpayer must be involved in the activity with continuity and regularity, and the taxpayer’s primary purpose for engaging in the activity must be for income or for profit. Id. at 35. Respondent alleges that as of the close of 2001, Mr. Deward had not begun the actual writing of his book on WWI, nor had he created an outline. Respondent argues that Mr. Deward was,Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007