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were insufficient funds in the Malone Music checking account,
petitioner would provide the needed funds, subject to
reimbursement from the Malone Music checking account if and when
funds became available. Petitioner viewed these advances as
small, short-term loans to Malone Music.
Malone Music does not advertise its services in any
established publication. From time to time, H and/or R create
and distribute leaflets and brochures for specific events or
classes offered by Malone Music in which they are identified as
the music leaders or “professors”. In an attempt to attract
students, R, with the assistance of N, created a Web site for
Malone Music. That Web site lists H and R as the only “contact
individuals” for Malone Music, and further identifies them as the
activity’s only instructors.
Petitioner assisted H and R with Malone Music for
approximately two-plus hours each week during the years in issue.
During those years, Mrs. Malone devoted approximately 8 hours per
week to helping out with Malone Music. Neither petitioner nor
Mrs. Malone provided any music lessons to anyone through Malone
Music. Petitioner describes petitioners’ involvement in Malone
Music as “primarily administrative”. Generally, petitioner
assisted with paying any necessary expenses and purchasing
musical instruments. At the outset of Malone Music, Mrs. Malone
would “from time to time” monitor the music instruction, but her
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Last modified: May 25, 2011