Christopher Joseph Bush and Robin Leigh Pickering - Page 5




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          as drafting a business plan or long-term financial analysis of              
          the profitability of Aspiring Artists.                                      
               As a result of petitioner’s efforts and Jennifer’s hard work           
          and skill, the New York Theatre Ballet (NYTB) extended her an               
          offer of employment.  Jennifer’s contract, entered into in August           
          of 1997, engaged her as an apprentice dancer from August through            
          December of 1997.  The period of the contract included training             
          and rehearsal time as well as 3 weeks of “The Nutcracker Ballet”            
          performances.  Both petitioners and Jennifer were overjoyed with            
          Jennifer’s success.                                                         
               On April 5, 2000, respondent sent to petitioners, by                   
          certified mail, a notice of deficiency.  The notice of deficiency           
          informed petitioners that respondent determined that the                    
          following $13,889 of Schedule C expenses petitioners deducted for           
          expenses related to their daughter’s dance education would not be           
          allowed:                                                                    


          Schedule C expenses deducted by petitioners            Allowed              
          Mileage                            $3,640              $    0               
          Advertising                        200                 200                  
          Wages                              525                 525                  
          Cost of goods sold                 150                 0                    
          Depreciation                       54                  54                   
          Employee benefits                  900                 0                    
          Supplies                           1,500               1,500                
          Meals                              900                 0                    
          Utilities                          500                 500                  
          Education and medical (other)      1,557               0                    
          Travel                             7,871               1,129                






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