- 4 - work related to a safety program, unrelated to the music business.2) At some indeterminate point petitioner conceived of a unique keyboard instruction system, which he called "Presto". Presto is a system of teaching keyboard techniques revolving around flexible lesson plans. Petitioner thought that his system could be marketed in the form of a video, software, written material, or another interactive form. He hoped it could be sold to school systems. However, petitioner did not actually produce any marketable video, software, or written material but instead continued to consider and investigate various possibilities. Petitioners have never received any gross income from the sale of any product associated with Presto. Petitioners reported losses on their Schedule C related to Presto for at least 8 consecutive years (1985 through 1992), claiming expenses during those years of more than $65,000. During 1992 and up to and including the time of trial, petitioner was still in the process of developing Presto. In 1992, petitioners maintained no separate bank account, had no customers, and kept no books for the Presto activity. Petitioners stipulated: “During the 1992 tax year there was no need for petitioners to maintain a separate bank account for the Presto activity because it was not an income 2 Respondent made no adjustments in the notice of deficiency regarding petitioners’ Schedule C for 1991. We therefore make no findings concerning it.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011