Gullion v. Comr. T.C. Sum. Op. 2013-65

(petitioner was a software designer with a six-figure income who also lost large sums in music endeavors; IRS denied deduction for substantial losses attributable to music activities under hobby loss rules; court disagreed on basis that factors favored petitioner; music activity was regular and continuous, petitioner had training in music, organized jazz festival, music industry has undergone change and petitioner attempted to change his music activity to become profitable; history of losses less persuasive in “art” field than in other fields and more time needed to achieve success in music than in other fields; court stated that petitioner’s six-figure income as software designer “modest”; elements of personal pleasure petitioner enjoyed in music activities did not negate profit motive).