Robert Dean Mazotti and Debra Lea Jones-Mazotti v. Comm., TCM 2024-75
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One and Two-Page Books do not an Author Make (Robert Dean Mazotti and Debra Lea Jones-Mazotti v. Comm., TCM 2024-75)
Debra Jones-Mazotti claimed to be a for-profit writer-researcher. The IRS classified her activity as not for profit in tax years 2018, 2019, and 2020. She had been claiming expenses as a writer-researcher for three decades before recording a profitable year in 2022. She traveled for her writing to California, Florida, and Hawaii. Her husband or daughter generally traveled with her. Trips to California and Disney World (Florida) were purportedly research on a family trivia game she wanted to write. On the trips, she took photos of fruits, vegetables, and trees for her writer-researcher activities. Three of her books submitted as exhibits were one or two pages in length (double-spaced). Her revenue for the three years 2018 – 2020 was $30, $15, and $1,000, respectively. Her expenses for the same years were $61,523, $63,019, and $62,470.
With little more than a few pages of books and a Trip Advisor review produced, the Court could not find any of the Treas. Reg. §1.183-2(b) factors in the taxpayer’s favor.