- 4 -
were similar to prior years. For a more detailed explanation as
to how petitioner conducted her tutoring activity, see Sexcius v.
Commissioner, T.C. Memo. 1993-310 and Sexcius v. Commissioner,
T.C. Memo. 1991-162.3
Petitioner tutored students for several hours every day
after school and also during the summer months and holidays,
devoting an average of 33 hours per week to such activity. She
charged minimally for her services, allowed customers to pay at
their discretion according to their ability to do so, and made
little or no effort to collect outstanding account receivables,
notwithstanding the substantial losses she incurred repeatedly
over several years. Other than the gross receipts reported on
Schedule C, petitioner provided little information with respect
to the amounts, if any, that she charged or received for her
services. She merely indicated that her fees were based upon
what she believed the students could pay, whether in cash or
other property. To petitioner, the fact that students or their
families could or could not pay for her services was secondary to
the fact that they needed the assistance that petitioner could
provide, and, for that reason, it was not petitioner's practice
3The parties stipulated to the trial transcripts in those
prior cases. At trial, the Court advised the parties that such
stipulations were being considered an invitation to base findings
of fact in this case upon testimony presented in the prior cases.
Neither party objected. To petitioner's detriment in this
proceeding, there was little if any change to petitioner's
methods of operation from one year to the next.
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