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Income Tax Keyed to Graetz
Storey v. Commissioner
Citation:
T.C. Memo 2012-115 (2012)Facts
In 2004, Petitioner, a successful law firm partner, began a project of producing and directing a feature-length documentary based on her husband’s former musical act. Petitioner claimed deductions based on business expenses for each year of her filmmaking project under Section 162 of the Internal Revenue Code. The Commissioner of Internal Revenue disallowed these deductions and asserted a deficiency against Petitioner, finding that she was not engaged in the business or trade of filmmaking and therefore could only claim deductions to the extent that she received income from the activity under Section 183 of the Internal Revenue Code.
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