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Dreicer v. Commissioner

United States Tax Court
78 T.C. 642 (1982)


Facts

Maurice Dreicer (plaintiff), a United States citizen, received a large annual income from his family’s trust fund. Dreicer lived abroad. Beginning in 1956, Dreicer spent an average of $25,000 each year engaging in foreign travel, which he enjoyed. Dreicer intended to profit from publishing books and making media appearances about his travel experiences. However, Dreicer’s one published book was a commercial failure. Dreicer claimed his 1972 and 1973 travel costs as tax-deductible business losses. The commissioner of internal revenue (commissioner) (defendant) disallowed Dreicer’s deductions, determining that Dreicer had traveled for enjoyment and not for profit. Dreicer petitioned the tax court for a redetermination. The tax court ruled for the commissioner, finding that Dreicer had no bona fide expectation of profiting from his travel experiences. Dreicer appealed to the United States Court of Appeals for the District of Columbia. The court of appeals held that, under § 183 of the federal tax code, the proper legal standard for determining the deductibility of a taxpayer’s expenses was the taxpayer’s objective of making a profit, not the taxpayer’s bona fide expectation of making a profit. The court of appeals reversed the tax court’s decision and instructed the tax court to apply the profit-objective standard to the facts on remand.

Rule of Law

Issue

Holding and Reasoning (Simpson, J.)

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