PORTER v. C. I. R.

No. 225, Docket 34725.

437 F.2d 39 (1970)

Louis H. PORTER, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided December 21, 1970.


Attorney(s) appearing for the Case

Louis H. Porter, pro se.

J. Robert Lunney, New York City, on the brief, for petitioner-appellant.

Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks, Leonard J. Henske, Jr., Richard Farber, Tax Division, Dept. of Justice, Washington, D.C., for respondent-appellee.

Before LUMBARD, Chief Judge, FEINBERG, Circuit Judge, and CLARIE, District Judge.


PER CURIAM:

The appellant is appealing from a decision of the Tax Court wherein it found him not to be engaged in carrying on the trade or business of an artist with the genuine expectation of realizing profits from such activities. This finding let stand the Commissioner of Internal Revenue's disallowance of the appellant's deductions under § 162(a) of the Internal Revenue Code (1954). We affirm the Tax Court's determination.

The applicable standard...

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