Fleischli v. Comm'r
United States Tax Court
In 2000, P had a net profit of more than $ 16,000 from the practice of law. P also earned $ 13,435 from acting activities and had acting-related expenses of $ 17,878 for 2000. A "qualified performing artist" may deduct from gross income employee business expenses related to his or her work as a performing artist if, inter alia, the individual has adjusted gross income (before deducting those business expenses) of not more than $ 16,000. Sec. 62(a)(2)(B), (b)(1), I.R.C.
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In 2000, P had a net profit of more than $ 16,000 from the practice of law. P also earned $ 13,435 from acting activities and had acting-related expenses of $ 17,878 for 2000. A "qualified performing artist" may deduct from gross income employee business expenses related to his or her work as a performing artist if, inter alia, the individual has adjusted gross income (before deducting those business expenses) of not more than $ 16,000. Sec. 62(a)(2)(B), (b)(1), I.R.C. P contends that "adjusted gross income" in sec. 62(b)(1)(C), I.R.C., includes only adjusted gross income from the performance…
1Opinion of the Court
JACK A. FLEISCHLI, A.K.A. JACK FORBES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Fleischli v. Comm'r
No. 5766-03
United States Tax Court
123 T.C. 59; 2004 U.S. Tax Ct. LEXIS 28; 123 T.C. No. 3;
July 14, 2004., Filed
Court determined that, for purposes of section 62(b)(1)(C), adjusted gross income means same as "adjusted gross income" in section 62(a) and thus must be computed based on taxpayer's gross income from all sources.
In 2000, P had a net profit of more than $ 16,000 from the
practice of law. P also earned $ 13,435 from acting activities
and had acting-related expenses of $…
2Cases cited14 opinions
- Carmichael v. Southern Coal & Coke Co.Supreme Court of the United States · 1937
- United States v. GonzalesSupreme Court of the United States · 1997
- Regan v. Taxation With Representation of WashingtonSupreme Court of the United States · 1983
- United States v. Maryland Savings-Share Ins. Corp.Supreme Court of the United States · 1970
- Barclay & Co. v. EdwardsSupreme Court of the United States · 1925
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