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artist activity as a Schedule C, Profit or Loss From Business,
sole proprietorship for Federal income tax purposes. Petitioner
reported net profits and losses for his two separate Schedule C
activities as follows:
Artist Accounting
Year Activity Activity
1984 ($544) ($3,272)
1985 (1,966) 6,334
1986 (617) 7,201
1987 (1,978) 10,063
1988 (7,959) 9,518
1989 (27,638) 16,824
1990 (27,300) 19,977
1991 (26,930) 26,930
1992 (31,774) 17,385
1993 (13,419) 13,419
1994 (18,384) 20,821
1995 (10,922) 19,951
1996 (934) 26,888
1997 (1,586) 17,737
1998 (4,071) -0-
For the years in issue, the relevant figures for petitioner’s
artist activity were as follows:
Artist Activity 1992 1993 1994 1995
Gross receipts $770 $320 $266 $357
Less deductions (32,544) (13,739) (18,650) (11,279)
Profit (Loss) (31,774) (13,419) (18,384) (10,922)
During the years in issue, petitioner did not support himself
with the income that he received from his artist activity, but
instead supported himself with the income that he received from
his accounting practice.
Petitioner provided adequate substantiation for the expenses
that he claimed on his tax returns. During the years in issue,
he kept a spreadsheet of income and expenses, a cash receipts
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