Corliss Lamont and Margaret I. Lamont v. Commissioner of Internal Revenue

LUMBARD, Chief Judge:

At issue in this petition are tax deductions claimed by taxpayer Corliss Lamont 1 as losses from his professional activities in the taxable year 1957. The Tax Court of the United States, Withey, J., disallowed the deductions, and upheld the Commissioner’s assessment of a $5,286.84 deficiency in taxpayer’s income taxes for that year. It found that Lamont’s activities as a teacher, writer, publisher, and lecturer were not carried on as a trade or business within the meaning of that term as used in §§ 162(a) and 165 of the Internal Revenue Code of 1954, 2 permitting…