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Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioner’s 2000
Federal income tax in the amount of $18,468, an addition to tax
under section 6651(a)(1) in the amount of $2,403, and a penalty
under section 6662(a) in the amount of $5,181.
The Court must decide whether petitioner is an employee and,
if so, whether he is entitled to deduct certain business
expenses, whether petitioner is entitled to deduct home office
expenses, whether petitioner is subject to an addition to tax
under section 6651(a)(1), and whether petitioner is subject to a
penalty under section 6662(a).
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Pasadena, California, at the
time he filed his petition.
During 2000, petitioner was a professional cellist. In
fact, he was and is internationally, as well as nationally,
recognized as a cellist of exceptional ability. Petitioner’s
career has many facets. His main focus is as a concert soloist.
He also teaches music. He does “studio work”, recording
background music for movies and television. Petitioner has
performed for about 600 motion pictures.
Petitioner is a founding member of the Pacific Trio,
together with pianist Edith Orloff. Petitioner is a faculty
member of Idyllwild Arts.
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