United States Tax Court
78 T.C. 642 (1982)
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
Holding and Reasoning (Simpson, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 221,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,100 briefs, keyed to 189 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.