Vitale v. Commissioner

Ralph Vitale (plaintiff), an author writing a novel about two men who traveled cross-country and started a brothel, made nearly three legal-brothel visits per month over a one-year period as research, meticulously recording each prostitute's characteristics and his negotiations, and telling some prostitutes he intended to use them as characters. Vitale deducted these brothel expenditures as business expenses on his tax return, and the commissioner (defendant) issued a deficiency notice; Vitale petitioned the tax court for redetermination.