Deductions: Home office expense: Investors v. Traders.
The taxpayers’ investment activities did not constitute a trade or business and they were not entitled to deduct the related expenses of their home offices. The taxpayers who managed their own extensive investments were investors and not traders because, although their investment activities were regular, extensive, and continuous, they were primarily interested in the long-term growth potential of their stocks, made few trades, and did not derive any significant profit from short-term trading.
BACK REFERENCES: 83FED ¶1330.517, 83FED ¶1332.1285 and 83FED ¶2297YT.52.
US-CT-APP-FC, [83-2 USTC ¶9698], Joseph A. and Dorothy D. Moller, Plaintiffs-Appellees v. The United States, Defendant-Appellant , Deductions: Home office expense: Investors v. Traders. -- (Nov. 18, 1983)
[83-2 USTC ¶9698]Joseph A. and Dorothy D. Moller, Plaintiffs-Appellees v. The United States, Defendant-Appellant
(CA-FC), U. S. Court of Appeals, Fed. Cir., Appeal No. 83-870, 721 F2d 810, 11/18/83, Reversing a decision of the Claims Court, 82-2 ustc ¶9694
[Code Secs. 162 and 280A]
