Christopher Joseph Bush and Robin Leigh Pickering - Page 2

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               Respondent determined that certain deductions were not                 
          ordinary and necessary expenses incurred while carrying on a                
          trade or business.  We must decide whether petitioners are                  
          entitled to deduct on Schedule C, Profit or Loss from Business,             
          cost of goods sold and various business expenses for 1996; we               
          hold that they are not.  We must also decide whether respondent’s           
          notice of deficiency is valid; we hold that it is.                          
               Some of the facts have been stipulated and are so found.               
          The exhibits received into evidence are incorporated herein by              
          reference.  At the time the petition in this case was filed,                
          petitioners resided in Alexandria, Virginia.  Petitioners are               
          husband and wife.  References to petitioner in the singular are             
          to Christopher Joseph Bush unless otherwise noted.                          
                                  FINDINGS OF FACT                                    
               In 1996, petitioner established Aspiring Artists, a sole               
          proprietorship whose stated purpose was to manage and develop               
          artistic talent.  In this pursuit, petitioner represented a band            
          and entered into an agreement with his stepdaughter Jennifer                
          Hummer (sometimes Jennifer or petitioners’ daughter or                      
          petitioner’s stepdaughter).                                                 
               Petitioners filed a joint return in 1996.  Petitioners                 
          attached to their 1996 Federal income tax return a Schedule C on            
          which they reported $3,550 of gross receipts and claimed various            
          deductions relating to Aspiring Artists.                                    

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