c30:No. 19367

HASTIE, Circuit Judge
(concurring).
I agree with the result reached in the circumstances of this case of a taxpayer who is engaged both in full time salaried employment as an engineer and in spare time uncompensated work as an evangelist. However, I am far from sure that the fact that expenses have been incurred in work undertaken without a profit motive is enough in itself and in all cases, as the Tax Court and this court seem to say, to preclude a deduction of expenses incurred in such activity from gross income as expenses of a “trade or business.” Upon that all comprehensive and unqualified proposition, I reserve judgment.

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