preview

Crile V. I. R.: Case Study

Decent Essays

Tori has had great success as a music performer, including successfully graduating with a Bachelor’s and Master’s Degree in Music from Juilliard and performing at distinguished venues such as Carnegie Hall, the Kennedy Center, and performing with the Boston Symphony for eight years. While an activity may not currently be profitable, it does not negate a taxpayer’s previous successful activities. As stated in Crile v. C.I.R., T. C. Memo. 2014-202 (2014), “a track record of success in other business ventures may indicate that the taxpayer has the...determination to success in subsequent endeavors.” Tori was extremely successful when she previously performed professionally. As Tori continues to build her network of contacts and performance …show more content…

Jazz Productions’ losses are not unusual for a new business and does not suggest a lack of profit motive. Losses sustained in the early years of a business are not indicative the business is operating for any reason other than to generate profits. As stated in Crile, “because it often takes years to achieve economic success in the creative arts, we have found that ‘a history of losses is less persuasive in the art field than it might be in other fields.” Tori is actively working to generate income for Jazz Productions to make it a profitable entity. Tori reaches out to promoters and nightclub owners to schedule performances to generate business income. Additionally she is developing new advertisements for her business and is working to establish a website for Jazz Productions to reach wider markets. Tori is operating Jazz Productions based on a profit motive. Tori recognizes while it takes time to develop the business, her focus is on making Jazz Productions profitable. The amount of occasional profits, if any, which are earned. Jazz Productions has not recorded a profit to date. However, Tori is working diligently with advertising and networking to make Jazz Productions a profitable

Get Access