Higgins v. Commissioner

Holding

Managing one's own investments, even extensively, did not amount to carrying on a trade or business for the deduction sought.

Facts

The taxpayer devoted substantial time and staff resources to supervising personal real estate, stocks, and bonds and claimed related deductions as business expenses.

Reasoning

The Court held that oversight of one's own investment portfolio did not itself become a trade or business simply because it was regular, organized, and large in scale.