Research Problem 6. Sam Adams is a CPA who is also an aspiring actor. In 2011, his AGI

(before any deductions for performing arts expenses) was $42,000 and was from the following sources:

CPA practice $30,000 Acting jobs (4 employers) 12,000 Expenses associated with his acting career were $9,000. Sam deducted these expenses under § 162 and classified them as deductions for AGI under § 62(a)(2)(B).

The IRS contends that the expenses are not eligible for treatment under § 62(a)(2)(B)

and should be classified as miscellaneous itemized deductions (subject to the 2%-of-AGI floor). According to the IRS, § 62(a)(2)(B) is not available because Sam has exceeded the AGI ceiling under § 62(b)(1)(C). Advise Sam on the appropriate tax treatment.