Dreicer v. Commissioner
United States Tax Court
Held, an examination of all the surrounding facts and circumstances of this case fails to convince us that P had an actual and honest objective to make a profit from his activities as a writer and a lecturer; therefore, such activities were not engaged in for profit within the meaning of sec. 183, I.R.C. 1954.
1Opinion of the Court
OPINION
Simpson, Judge:
In Dreicer v. Commissioner, T.C. Memo. 1979-395 (39 T.C.M. 233, 48 P-H Memo T.C. par. 79,395), we sustained the Commissioner’s determination that, based on all of the facts and circumstances of that case, Mr. Dreicer’s activities as a writer and lecturer were not engaged in for profit within the meaning of section 183, Internal Revenue Code of 1954.1 Mr. Dreicer appealed such decision to the Court of Appeals for the District of Columbia Circuit. That court, although it sustained our factual findings, reversed such decision on the ground that we had applied an erroneous…
2Cases cited12 opinions
- Engdahl v. CommissionerUnited States Tax Court · 1979
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- Brannen v. CommissionerUnited States Tax Court · 1982
- Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Dunn v. CommissionerUnited States Tax Court · 1978
7 more not listed; retrieve them via the Exa API.
3Cited by627 opinions
- Beck v. CommissionerUnited States Tax Court · 1985
- Surloff v. CommissionerUnited States Tax Court · 1983
- Fox v. CommissionerUnited States Tax Court · 1983
- Antonides v. CommissionerUnited States Tax Court · 1988
- Estate of Baron v. CommissionerUnited States Tax Court · 1984
622 more not listed; retrieve them via the Exa API.