Jack Chien Ching Huang - Page 4




                                        - 3 -                                         
               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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