Churchman v. Commissioner
United States Tax Court
Petitioner is an artist who has been involved in artistic activities for 20 years. Held: Petitioner's testimony and the objective evidence clearly establish that petitioner is a most dedicated artist who pursued her artistic activities during the years in question with the bona fide intention and expectation of making a profit.
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Petitioner is an artist who has been involved in artistic activities for 20 years. Held: Petitioner's testimony and the objective evidence clearly establish that petitioner is a most dedicated artist who pursued her artistic activities during the years in question with the bona fide intention and expectation of making a profit. Having established such fact, it seems to us irrelevant whether petitioner intends to make a profit because it symbolizes success in her chosen career or because it is the pathway to material wealth. Therefore, petitioner's artistic activities were engaged in for…
1Opinion of the Court
Forrester, Judge:
Respondent has determined the following deficiencies in petitioner’s Federal income taxes:
Taxable year Amount of deficiency
1970. $2,491.33
1971. 1,053.00
1972. 1,178.00
Concessions having been made, the sole issue presented for our decision is whether the artistic activities of petitioner Gloria Churchman were not engaged in for profit so that section 1831 applies.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners C. West and Gloria Churchman, husband and wife, resided in Mill Valley, Calif., at the time they filed the petition herein.…
2Cases cited4 opinions
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Clement L. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Benz v. CommissionerUnited States Tax Court · 1974
3Cited by87 opinions
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Golanty v. CommissionerUnited States Tax Court · 1979
- Engdahl v. CommissionerUnited States Tax Court · 1979
- Brannen v. CommissionerUnited States Tax Court · 1982
- Allen v. CommissionerUnited States Tax Court · 1979
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