DREICER V. COMMISSIONER
78 T.C. 642 (1982)
NATURE OF THE CASE: Dreicer (P) appealed a determination that P's activities as a writer
and lecturer were not engaged in for profit within the meaning of I.R.C. 183. The case
was before the court on remand from the Court of Appeals for the District of Columbia
Circuit.
FACTS: P spent years and a small fortune traveling around the world. P claimed it was to
be able to write a travel book. P did write the book but it was rejected by two publishing
companies. P claimed losses of around $50,000 for travel expenses. The IRS (D) disallowed
the deductions in that from the facts it deemed that P did not do the activities involved in
an honest pursuit of profit. It held that P had no reasonable expectation of profit.
Eventually the court of appeals reversed and remanded the case because the tax court did not
use the proper legal standard.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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