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Section 183(b)(2) provides that a taxpayer may deduct an amount "equal to the amount of the deductions which would be allowable [ . . . ] only if such activity were engaged in for profit, but only to the extent that the gross income derived from such activity for the taxable year exceeds the deductions allowable [ . . .
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The next requirement of section 162(a) is that the taxpayer must be carrying on a trade or business. [2] Start up expenses are not entirely deductible, but must be spread out over 15 years. [10] Because business expenses are fully deductible under section 162, taxpayers try to argue that expenses were not start up expenses.
After seeing him correctly predict six football games in a row, the patrons are enamored when he returns to the bar the next week and claims "football is a hobby, my real business is the stock market". He receives an influx of new business and tells his new customers that the market is "adjusting" any time the Dow-Jones Industrial Average drops.
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