Jin Xiong - Page 8

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          did not have an “employer” with respect to his book writing                 
          project.  It is for this reason that petitioner amended his 2003            
          return to recharacterize these expenses as “profit/loss from a              
          separate business activity.”                                                
               Petitioner has not convinced us that his book writing                  
          project is a separate activity rather than an outgrowth of his              
          university teaching and research.  While it may be true, as                 
          petitioner suggests, that university professors generally are not           
          required to write books, it does not follow that a university               
          professor who writes a book is engaged in a separate business               
          activity.  Petitioner’s book is in the same academic discipline             
          as the one petitioner teaches at the university.  Petitioner’s              
          contract with Cambridge University Press clearly identifies                 
          petitioner as a university professor.  Petitioner based his book,           
          at least in part, on teaching notes he had developed over the               
          years, and he used the book in teaching courses at the                      
          university.  We find that petitioner’s book writing project is so           
          interconnected with his university teaching and research as to              
          not constitute an activity separate from that of his occupation             
          as a university professor.  See Topping v. Commissioner, T.C.               
          Memo. 2007-92.                                                              
               A taxpayer may have only one principal place of business for           
          each business activity in which he is engaged.  Curphey v.                  
          Commissioner, 73 T.C. 766, 775-776 (1980).  Where a taxpayer’s              

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