Crile v. IRS, TC Memo 2014-202 (Oct. 2, 2014).
Yesterday's Crile v. IRS, TC Memo 2014-202 provides an interesting analysis of an artist's successful use of IRC Sec. 162 to deduct her business expenses and losses she incurred as an artist. In Crile, the taxpayer was an artist and a tenured art professor. The IRS successfully separated her artist activities from her art professor activities. However, the IRS's was unsuccessful arguing that the taxpayer's art was too enjoyable and not profitable enough to satisfy the profit motive or "ordinary and necessary" business expense requirements of Sec. 162. Disposed for the taxpayer.
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