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DE GRAZIA v. COMMISSIONER

Docket No. 89972.

21 T.C.M. 1572 (1962)

T.C. Memo. 1962-296

Sebastian de Grazia and Anna Maria de Grazia v. Commissioner.

United States Tax Court.

Filed December 18, 1962.

Attorney(s) appearing for the Case

Burton A. Friedman, Esq., 117 W. 197th St., New York, N. Y., for the petitioners.

Chapman H. Belew, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

The respondent has determined a deficiency in the income tax of the petitioners for the calendar year 1957 in the amount of $1,295. Certain adjustments have been agreed to and the sole remaining issues are whether petitioner was in the "trade or business" of being an artist during the taxable year, and if so, the amount of expenses attributable to said "trade or business."1

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