ROBERTS v. C.I.R.

No. 15-3396.

820 F.3d 247 (2016)

Merrill C. ROBERTS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided April 15, 2016.


Attorney(s) appearing for the Case

Richard W. Craigo , Attorney, Law Offices of Richard W. Craigo, Los Angeles, CA, for Petitioner-Appellant.

Curtis C. Pett , Attorney, Joan I. Oppenheimer , Attorney, Department of Justice, Washington, DC, for Respondent-Appellee.

Before POSNER, EASTERBROOK, and WILLIAMS, Circuit Judges.


The Internal Revenue Code allows a taxpayer to deduct "all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business." 26 U.S.C. § 162(a). But if the activity giving rise to the expenses "is not engaged in for profit," section 183 permits deduction of expenses incurred...

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