- 2 - Respondent determined a deficiency in petitioner’s 1994 Federal income tax in the amount of $6,337. Respondent disallowed petitioner’s deduction of $30,684 for expenses claimed on a Schedule C, Profit or Loss From Business, on the grounds that petitioner did not engage in an activity for the purpose of making a profit. An automatic adjustment was made. This Court must decide whether petitioner engaged in a tutoring activity for profit within the meaning of section 183. Some of the facts in this case have been stipulated and are so found. Petitioner resided in Los Angeles, California, at the time she filed her petition. During 1994, petitioner was employed as a teacher with the Los Angeles Unified School District (LAUSD). She earned wages of $54,610. Petitioner taught at Richland Elementary School (Richland). As a teacher at Richland, petitioner taught first grade students from January through June 1994, and third and fourth grade students from September through December 1994. On her Federal income tax return for 1994, petitioner claimed deductions for an alleged activity she called Conversation with Connection (CWC). In the alleged activity CWC, petitioner claimed she tutored students (not at or from Richland) about the use of computers. The year at issue was the second year that petitioner’s tax returns reflected the alleged activity called CWC.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011