Sharon T. Myrick - Page 5




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               Section 162 generally allows a deduction for all ordinary              
          and necessary expenses paid or incurred during the taxable year             
          in carrying on a trade or business.  Such expenses must be                  
          directly connected with or pertain to the taxpayer’s trade or               
          business.  Sec. 1.162-1(a), Income Tax Regs.  Whether a                     
          taxpayer’s activities constitute the carrying on of a trade or              
          business is a question of fact requiring an examination of the              
          particular facts and circumstances of each case.  Commissioner v.           
          Groetzinger, 480 U.S. 23, 36 (1987).  We decide whether                     
          petitioner has established that she engaged in a trade or                   
          business in 2002 on a preponderance of the evidence.                        
               In order to establish that he or she was engaged in a trade            
          or business, the taxpayer must be continuously and regularly                
          involved in the activity for the primary purpose of making a                
          profit.  Id. at 35.  “While the focus of the test for whether a             
          taxpayer engaged in an activity with the intention of making a              
          profit is on the subjective intention of the taxpayer, greater              
          weight is given to the objective facts than is given to the                 
          taxpayer’s mere statement of his intent.”  Wesley v.                        
          Commissioner, T.C. Memo. 2007-78; see also sec. 1.183-2(a),                 
          Income Tax Regs.                                                            
               Petitioner claims that she was engaged in an event-planning            
          business in 2002.  Petitioner provided some documents in an                 
          attempt to demonstrate that she operated a business and to                  







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