- 2 -
After concessions by respondent,2 the issues for decision
are: (1) Whether petitioners are entitled to the claimed
employee expenses on Schedule A for: Home office $3,600,
electricity $109, telephone $505, car and truck $3,346, meals and
entertainment $1,479, and clothing $1,296; (2) whether
petitioners are entitled to a claimed Schedule C deduction of
$1,180 for travel; and (3) whether petitioners are liable for the
accuracy-related penalty under section 6662(a) for negligence or
disregard of rules or regulations.
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
their petition, petitioners resided in Beverly Hills, California.
Schedule A
Katia Popov (Mrs. Popov) is a professional violinist.
During 1993, Mrs. Popov played with the Los Angeles Chamber
Orchestra and the Long Beach Symphony. Additionally, Mrs. Popov
played in orchestras which recorded music for the motion picture
industry. For example, a contractor (from MGM, Paramount,
Universal, etc.) would call Mrs. Popov to tell her that he was
putting together an orchestra to record music for a motion
picture. When the contractor called, either Mrs. or Mr. Popov
2 In the notice of deficiency, respondent disallowed
certain expenses which were claimed on Schedule C-1 pertaining to
Mrs. Popov’s business. Respondent now concedes these items.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011