Bruce Millard - Page 3




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               The issue for decision is whether petitioner is entitled to            
          trade or business expense deductions in excess of the amounts               
          allowed by respondent.  Agreements between the parties allow                
          resolution of the issue to depend entirely upon the extent to               
          which petitioner can substantiate the expenditures that underlie            
          those deductions.2                                                          
                                     Background                                       
               Some of the facts have been stipulated and are so found.  At           
          the time the petition was filed, petitioner resided in Jamaica              
          Plain, Massachusetts.                                                       
               During the year in issue, petitioner was employed in various           
          ways relating to the music industry.  He was self-employed as a             
          music teacher3 and performance artist.  He also taught students             
          as an employee for the Brookline Music School (Brookline).  As a            
          self-employed music teacher, petitioner provided music lessons to           
          his students (petitioner’s private students) either at a music              
          studio in Milford, Massachusetts, or at petitioner’s residence.             
          Music lessons for some of the students that petitioner taught as            
          an employee of Brookline (Brookline’s students) were conducted              




               2 There are no disputes between the parties regarding the              
          technical applications of the relevant provisions of the Internal           
          Revenue Code, including secs. 162, 274, 280A, and 280F.                     
               3 Petitioner instructed students learning to play various              
          stringed instruments, including the guitar and mandolin.                    





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