Jane Anne Jeffries - Page 3




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               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.                                                                 





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