Protest Letter

739 Words Apr 3rd, 2011 3 Pages
1612 State Street, Suite 1700
Seattle, WA 98001

August 8, 2010

District Director
Seattle Appeals Office
Internal Revenue Service
915 Second Avenue, M/S 680, Room 2790
Seattle, WA 98174

Re: Protest of Ican Wright SS No: 555-55-5555

Dear District Director:
On behalf of the taxpayer, Ican Wright, protest is hereby made to the adjustments in individual income tax deductions as set forth in March 15, 2010 30-day letter. The following information is submitted in support of this protest.

1. NAME AND ADDRESSES OF TAXPAYER

Ican Wright
55555 NE 40th Street
Redmond, WA 98051
(555) 555-5555

2. STATEMENT OF APPEAL

The taxpayer requests an appeal of the findings of the IRS to the Appeals Office.

3. DATES AND
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The taxpayer hereby requests that the taxpayer’s case be referred to the Seattle Appeals Office of the Internal Revenue Service.

7. STATEMENT OF LAW

The examining agent’s report raises the following legal issue:

A. Proper Deduction of Work-Related Travel Expenses in 2009.

(1) Procedural Background.

Ican took $15,000 deduction for work-related expenses in arriving at his adjusted gross income in 2009.

(2) Deduction of Work-Related Expenses in 2009.

All ordinary and necessary expenses paid or incurred in carrying on any trade or business are deductible. To be considered engaged in a trade or business there has to be continuity and regularity. In addition profit must be the primary or dominant purpose for engaging in the activity.

Ican is in the business of writing books and deducted traveling expenses incurred while researching, writing, and arranging material for a book in accordance with section 162. He has devoted the last two years to his writing and has published one book. His writing is his only source of income. Although making a profit is not the only way to show that you are in the business of writing. He in fact has made a profit by publishing one book and has been given an advance on his current book. All this further solidifies that Ican is engaged in writing for a profit. In addition, unlike in Royster v Commissioner all of the expenses incurred by Ican have been properly
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