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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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Last modified: November 10, 2007