- 2 - 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.Page: Previous 1 2 3 4 5 6 NextLast modified: November 10, 2007