George Kukes and Margaret Kukes - Page 4

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            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.                                                     



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