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accuracy-related penalty under section 6662(a) in the amount of
$226. After concessions by respondent, this Court must decide:
(1) Whether petitioner wife's educational expenses are deductible
under section 162; (2) whether petitioners are entitled to deduct
home office expenses under section 280A; and (3) whether
petitioners are liable for an accuracy-related penalty for
negligence under section 6662(a).
For clarity and convenience, the findings of fact and
opinion have been combined.
Some of the facts have been stipulated and are so found.
Petitioners resided in Oklahoma City, Oklahoma, at the time they
filed their petition.
Petitioner Lois A. Hewett (petitioner) is a professionally
trained pianist. She received both a bachelor's and a master's
degree in music from the University of Michigan in 1953 and 1954,
respectively. She also completed all the course work, but not
the final series of exams and recitals, for a doctorate in music
arts from the University of Illinois.
Petitioner has taught piano both privately and at various
universities since the 1950's, including the University of
Oklahoma. During her 25 years of teaching at the University of
Oklahoma, petitioner principally taught piano, one-on-one, to
students. She also taught music theory, improvisation, sight
reading, accompanying, and ensemble.
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