Akey v. Comm'r
United States Tax Court
R disallowed P's costs of goods sold and deductions for expenses relating to his sports memorabilia activity and to his computer activity. R disallowed those costs and deductions relating to the memorabilia activity on the grounds that P had failed to show that the activity was an activity engaged in for profit or, if it was, that P had substantiated those expenditures.
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R disallowed P's costs of goods sold and deductions for expenses relating to his sports memorabilia activity and to his computer activity. R disallowed those costs and deductions relating to the memorabilia activity on the grounds that P had failed to show that the activity was an activity engaged in for profit or, if it was, that P had substantiated those expenditures. R disallowed the costs and deductions relating to the computer activity for lack of substantiation. 1. Held: R's denial of deductions is sustained for P's lack of substantiation and, with respect to the memorabilia activity,…
1Opinion of the Court
TERRY GENE AKEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Akey v. Comm'r
Docket Nos. 18026-05, 18097-05, 28057-09
United States Tax Court
T.C. Memo 2014-211; 2014 Tax Ct. Memo LEXIS 206; 108 T.C.M. (CCH) 433;
October 8, 2014, Filed
Decisions will be entered under Rule 155.
R disallowed P's costs of goods sold and deductions for expenses relating to his sports memorabilia activity and to his computer activity. R disallowed those costs and deductions relating to the memorabilia activity on the grounds that P had failed to show that the activity was an activity engaged in for profit…
2Cases cited16 opinions
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Tokarski v. CommissionerUnited States Tax Court · 1986
- Golanty v. CommissionerUnited States Tax Court · 1979
11 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- McMillan v. Comm'rUnited States Tax Court · 2015
- Terry Gene Akey v. CommissionerUnited States Tax Court · 2014