Sherman v. Commissioner
United States Tax Court
On the facts,held, (1) P's writing activity was not carried on with an actual and honest objective of making a profit. Dreicer v. Commissioner,78 T.C. 642, 646 (1982), affd, without opinion 702 F.2d 1205 (D.C.
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On the facts,held, (1) P's writing activity was not carried on with an actual and honest objective of making a profit. Dreicer v. Commissioner,78 T.C. 642, 646 (1982), affd, without opinion 702 F.2d 1205 (D.C. Cir. 1983); (2) Ps are not entitled to a dependency exemption deduction under I.R.C. sections 151 and 152(a); (3) Ps are not liable for the addition to tax for negligence under I.R.C. sections 6653(a)(1) and (2); and (4) Ps are liable for the late filing addition under I.R.C. section 6651(a)(1).
1Opinion of the Court
BRADLEY LEE AND JOY A. SHERMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sherman v. Commissioner
Docket No. 10803-86.
United States Tax Court
T.C. Memo 1989-269; 1989 Tax Ct. Memo LEXIS 269; 57 T.C.M. (CCH) 599; T.C.M. (RIA) 89269;
June 7, 1989.
On the facts,held, (1) P's writing activity was not carried on with an actual and honest objective of making a profit. Dreicer v. Commissioner,78 T.C. 642, 646 (1982), affd, without opinion 702 F.2d 1205 (D.C. Cir. 1983); (2) Ps are not entitled to a dependency exemption deduction under I.R.C. sections 151 and 152(a); (3) Ps are not…
2Cases cited4 opinions
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Vance v. CommissionerUnited States Tax Court · 1961
- Blanco v. CommissionerUnited States Tax Court · 1971
- Stafford v. CommissionerUnited States Tax Court · 1966
3Cited by3 opinions
- Goldenberg v. CommissionerUnited States Tax Court · 1993
- Moody v. CommissionerUnited States Tax Court · 1991
- Rosenblatt v. Comm'rUnited States Tax Court · 2008