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either at Brookline’s facility, or as in the case of his private
students, at petitioner’s residence.
Petitioner also performed roughly four to eight times per
month during 2001, generally at small clubs, but occasionally at
music festivals. From time to time he was also hired to be a
“side man,” which required that he accompany groups of musicians
on out-of-town trips that often involved overnight stays.
During 2001, petitioner lived in an old house that had been
converted into several apartments. Petitioner rents one of the
apartments from the owner of the house and, as relevant here,
during 2001, paid rent and utilities expenses in the amounts of
$16,625 and $1,173, respectively. Petitioner’s apartment
occupies portions of two levels of the house, and in addition to
hallway spaces, consists of at least six distinct rooms that
spread out over approximately 1,570 square feet. Petitioner
estimates that at least 776 square feet (49.40 percent of the
apartment) was used exclusively for business purposes.
Petitioner and his spouse, who is not a party to this
proceeding, filed a timely joint 2001 Federal income tax return
(petitioner’s return). Petitioner’s return includes a Schedule
A, Itemized Deductions, and a Schedule C, Profit or Loss From
Business. Expenses attributable to petitioner’s employment with
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Last modified: November 10, 2007