Paula M. Kelly - Page 2




                                          2                                           
               Respondent determined a deficiency in petitioner's Federal             
          income tax in the amount of $2,256 for the 1994 tax year.                   
               After a concession,1 the remaining issues for decision are:            
          (1) Whether petitioner is entitled to claim Schedule C expenses             
          for the 1994 tax year, and (2) whether petitioner is entitled to            
          an earned income credit for 1994.                                           
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time the petition            
          was filed, petitioner resided in Milton, Massachusetts.                     
                                  FINDINGS OF FACT                                    
               In 1994, petitioner worked in the entertainment media                  
          providing freelance makeup services for actors and models working           
          in film, television, theater, and still photography.  During this           
          time petitioner was also a member of the Makeup and Hair Stylists           
          Local Union 798 I.T.S.E. of New York, New York.                             
               Petitioner obtained work in the industry by reading various            
          trade publications and by contacting production companies                   
          bringing theatrical productions to the Boston area.  Petitioner             
          also apparently obtained some work by referral.  Once petitioner            
          knew there would be work available on a certain date, petitioner            
          sent her resume to companies that might hire her.  Parties                  


          1    Respondent concedes that petitioner reported rental income             
          in the amount of $675 on Schedule C of petitioner's 1994 return.            




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