Katia V. and Peter Popov - Page 2

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               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.                




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