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A. Petitioner
During 1997, the taxable year in issue, petitioner operated
a small after-hours school, gave private violin lessons, and was
a composer of musical scores. We examine each of petitioner’s
businesses in turn.
B. The Pasadena Chinese School
In 1994, after achieving a bachelor of arts degree in music
from the University of California at Irvine, a degree in film
scoring from the University of California at Los Angeles, and a
commercial music degree from California State University at Los
Angeles, petitioner founded a small after-hours school in
Pasadena, California, called the Pasadena Chinese School. The
City of Pasadena granted petitioner a business license for the
“Pasadena Chinese School/CIM Music Productions providing classes
of Chinese and Fine Arts” on the condition that petitioner rent
another facility outside his home for classroom use.3
During 1997, petitioner rented classroom space at Wilson
Middle School (Wilson), a public school within the Pasadena
Unified School District. Petitioner used this space to teach
courses in music, mathematics, martial arts, English, and Chinese
to students between the ages of 5 and 12. The space was
3 Petitioner’s arrangement with the City of Pasadena did
permit petitioner to maintain an office in the home.
Petitioner’s business address, as specified on the license, was
75 South Meridith Avenue, Pasadena, CA. See infra “E”.
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