Jack Chien Ching Huang - Page 7




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                    2.  “Studio”                                                      
               Petitioner referred to the second of his two rooms as a                
          “studio”.  This room measured 11 feet 2 inches in width by 15               
          feet in length.  The room included an electronic musical                    
          keyboard, sound recording equipment, loud speakers, a computer              
          (with a musical instrument digital interface) and monitor, and              
          shelves containing a multitude of music tapes.  The room also               
          included a folding sofa, which petitioner would use as a bed if             
          he worked late at night composing music.  Finally, there was a              
          closet, which petitioner used to store both personal and business           
          belongings.                                                                 
               Petitioner exclusively used a clearly defined portion of               
          this room, equal to three-quarters of its square footage, to: (1)           
          Prepare lesson plans and perform other tasks related to his                 
          duties as the administrator/teacher at the Pasadena Chinese                 
          School; (2) compose music for CIM Music Productions; and (3)                
          teach most of his Saturday violin lessons.                                  
               F.  Loan Repayment                                                     
               Petitioner maintained an account with Providian Bank in the            
          form of a line of credit.  Petitioner borrowed against this line            
          of credit in order to pay operating expenses of the Pasadena                
          Chinese School.  Petitioner deducted such operating expenses on             
          his Schedule C, which deductions were allowed by respondent.                
               In March 1997, petitioner borrowed $5,000 from his mother.             






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