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incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Washington, D.C.
FINDINGS OF FACT
During 1989, petitioner was employed on a full-time basis as
a teacher in the District of Columbia Public School System.
Petitioner holds a bachelor of science degree and a master's
degree, and is certified to teach biology at the senior high
school level. Petitioner is also a registered nurse and during
the year in issue was employed on a part-time basis with
Medlantic Long Term Care Corp. as a nurse on weekends and
holidays.
Beginning in 1979 and continuing at least through 1991,
petitioner engaged in a tutoring and counseling activity (the
tutoring activity). For the years 1979 through 1991, without
data available for years 1981 and 1990, petitioner reported
Schedule C gross receipts in the aggregate amount of $36,880, and
other income on Schedule C in the aggregate amount of $6,275, and
claimed total deductions of $172,868.55 that resulted in a loss
for each year, and an aggregate loss in the amount of
$129,713.55. Petitioner provided her tutoring and counseling
services primarily to individuals from low income, impoverished
families. Petitioner operated the activity in 1989 in a similar
manner to its operation in prior years. Thus, the general set up
of the activity, the number of students tutored, the time she
devoted to the activity, and various other policies and practices
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