ART FOR IRS’ SAKE: HOBBY LOSS RULES AND ARTISTIC ENDEAVORS

In Crile v. Commissioner, T. C. Memo. 2014-202 (Oct. 2, 2014), the United States Tax Court recently ruled that a tenured art professor’s artistic endeavors constituted a “business” rather than a “hobby.” Internal Revenue Code Section 183 limits taxpayers’ deductions to the extent of income earned if the activity is not engaged in for profit, i.e. a hobby, rather than a business. In this presentation, we examine the nine factors considered by the court in distinguishing between businesses and hobbies and discuss how the facts and circumstances of the taxpayer in this case prompted the court to decide in her favor. Practical recommendations are made to assist taxpayers to determine whether their art constitutes a hobby or an activity engaged in for profit and how to strategize their activities so that they too can deduct expenses despite the fact that a profit may not have been realized

Impact of cavitron ultrasonic surgical aspirator (CUSA) and bipolar radiofrequency device (Habib-4X) based hepatectomy for hepatocellular carcinoma on tumour recurrence and disease-free survival

Background: The aim of this study was to evaluate the oncological outcomes of hepatocellular carcinoma patients undergoing liver resection using cavitron ultrasonic surgical aspirator (CUSA) or radiofrequency (RF) based device Habib-4X. Study Design: We prospectively analyzed the data of 280 patients who underwent liver resection for hepatocellular carcinoma at our institution from 2010–2012 with follow up till August 2016. The CUSA was used in the 163 patients whilst Habib-4X in 117 patients. The end points of analysis were oncological outcomes as disease recurrence, disease-free survival (DFS) and overall survival (OS) were estimated by the Kaplan–Meier method, which has been compared with all other existing literature on the survival study. Results: Compared with CUSA the reported incidence of recurrence was significantly lower, in Habib-4X group; p < 0.01. The median DFS was significantly better in Habib-4X group than CUSA group (50.80 vs 45.87 months, p = 0.03). The median OS was better in Habib-4X group than CUSA group (60.57 vs 57.17 months, p = 0.12) though the lesser difference in OS between the groups might be explained by the use of palliative therapies as TACE, percutaneous RFA, etc. in case of recurrence. Conclusions: RF based device Habib-4X, is safe and effective device for resection of hepatocellular carcinoma, in comparison to CUSA with better oncological outcomes, i.e., significantly lesser tumour recurrence and better DFS. This could be explained on the basis of systemic and local immunomodulatory effect involving induction of kupffer cells and effector CD-8 T cells that help in minimizing postoperative complications and bring more advantageous oncological outcomes