Herbert F. and Lois A. Hewett - Page 5

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               After she had completed sufficient course work, petitioner             
          worked as a music therapist in a summer program at Hope Community           
          Center in Oklahoma City, Oklahoma.  Hope Community Center is a              
          community mental health treatment center.   Petitioner also has             
          worked as a music therapist with Alzheimer's patients in a                  
          nursing home, as well as with school children suffering from                
          problems such as developmental delay, microcephaly, and cerebral            
          palsy.                                                                      
               As of the time of trial, petitioner had interviewed for                
          employment as a music therapist at St. Anthony's Hospital and               
          Deaconess Hospital.  Both positions were with the                           
          psychiatric/mental health departments of the respective                     
          hospitals.  Petitioner had also interviewed for a music therapist           
          position with the Red Rock Community Center.                                
               Respondent disallowed the following expenses claimed by                
          petitioners on the Schedule C attached to their 1989 Federal                
          income tax return:                                                          
               Education expenses                 $2,501                              
               Home office expenses               255                                 
               Depreciation                       472                                 
               Telephone expenses                 35                                  
               Professional dues                  158                                 
               Petitioners now claim additional Schedule C educational                
          expenses of $1,665 for 1989.                                                
               Section 162 allows a deduction for ordinary and necessary              
          business expenses.  Educational expenses are deductible business            
          expenses when the education maintains or improves the skills                




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