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P spent years and a small fortune traveling around the world. P claimed it was to be able to write a travel book. P did write the book, but it was rejected by two publishing companies. P claimed losses of around $50,000 for travel expenses. The IRS (D) disallowed the deductions in that from the facts it deemed that P did not do the activities involved in an honest pursuit of profit. It held that P had no reasonable expectation of profit. Eventually, the court of appeals reversed and remanded the case because the tax court did not use the proper legal standard.

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