Katia V. and Peter Popov - Page 3

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          would record the time and place of the recording session in Mrs.            
          Popov’s calendar.  Mrs. Popov worked for 24 contractors during              
          1993 and recorded at 38 locations.  The recording sessions were             
          scheduled in either 3- or 6-hour blocks of time, and Mrs. Popov             
          was paid by the contractor.  Mrs. Popov received a total of 26              
          Forms W-2 for 1993.                                                         
               In the notice of deficiency, respondent disallowed the                 
          Schedule A expenses, stating that petitioners have not                      
          established that the expenses were paid or incurred during the              
          taxable year, or if the expenses were incurred, petitioners have            
          not shown that these are deductible expenses.  At trial,                    
          respondent further contended that the car and truck and the meals           
          and entertainment expenses lacked substantiation.                           
               Section 162(a) permits the deduction of "ordinary and                  
          necessary" expenses paid or incurred during the taxable year in             
          carrying on any trade or business.  Taxpayers must keep                     
          sufficient records to establish deduction amounts.  Sec. 6001;              
          Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965).                     
          Home Office and Electricity                                                 
               Neither the various contractors, the Los Angeles Chamber               
          Orchestra, nor the Long Beach Symphony provided a place for Mrs.            
          Popov to practice, although it was expected that the musicians              
          would practice daily.  For the recording sessions, Mrs. Popov               
          would not receive the sheet music in advance in order to                    
          rehearse.  Once the musicians arrived at the studio, they would             




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