Storey v. Comr., T.C. Memo. 2012-115

(petitioner made movie and deducted production expenses; IRS disallowed deduction under hobby loss rules, but court found requisite profit intent present under I.R.C. Sec. 183; petitioner also made Sec. 181 election to expense production costs and established substantial compliance with statutory requirements for election; IRS post-trial brief detailing petitioner's lack of conformity with requirements of regulations not admissible evidence and too lengthy).