Garrison v. Commissioner
United States Tax Court
During the taxable year in issue, petitioner was in the trade or business of being an author and incurred expenses in writing a book.
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During the taxable year in issue, petitioner was in the trade or business of being an author and incurred expenses in writing a book. Petitioner claimed current deductions for these expenditures which respondent disallowed on the basis that these amounts were subject to the capitalization requirements of sec. 280, I.R.C. 1954. Held, expenses incurred by an author in writing a book are subject to the provisions of sec. 280. Held, further, the effective date provision of sec. 280 does not exclude petitioner from the statute's coverage. Held, further, respondent is not precluded from applying…
1Opinion of the Court
STERRETT, Chief Judge:
By notice of deficiency dated June 16, 1983, respondent determined a deficiency in petitioners’ Federal income tax for the taxable year ended December 31, 1980, in the amount of $928. The issues for resolution are (1) whether expenses petitioner incurred as an author in writing a book are subject to the provisions of section 280,1 (2) if section 280 applies to authors, whether petitioner is excluded from its coverage by the statute’s effective date provision, and (3) if section 280 applies to authors, whether respondent is precluded from applying the statute by virtue of…
2Cases cited3 opinions
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Paul Snyder and Helen J. Snyder v. United StatesCourt of Appeals for the Tenth Circuit · 1982
- Faura v. CommissionerUnited States Tax Court · 1980
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- Arthur T. Hadley and Susan K. Bryant v. Commissioner of Internal Revenue, Lloyd McKim Garrison and Sarah Garrison v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1987
- "Miss Elizabeth" D. Leckie Scholarship Fund v. CommissionerUnited States Tax Court · 1986
- Crouch v. CommissionerUnited States Tax Court · 1990
- "Miss Elizabeth" D. Leckie Scholarship Fund v. CommissionerUnited States Tax Court · 1986
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