Bruce Millard - Page 5




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          Brookline are deducted as part of the miscellaneous itemized                
          deduction claimed on the Schedule A.                                        
               The Schedule C shows petitioner’s “principal business or               
          profession” as “music performance and production,” and expenses             
          attributable to petitioner’s various activities as a music                  
          instructor and performing artist, including home office expenses,           
          are deducted on this schedule.                                              
               In the notice of deficiency that forms the basis for this              
          case various adjustments, some in petitioner’s favor, are made to           
          the above-referenced deductions.  There is no point in providing            
          the detail of those adjustments here because the parties, much to           
          their credit, have by their agreements moved beyond the disputes            
          suggested by those adjustments.                                             
                                     Discussion                                       
               The extent to which the parties have reached agreement on              
          many of the adjustments leaves us little to do other than examine           
          the evidence presented, both in the form of documents and                   
          testimony, in order to determine whether petitioner has properly            
          substantiated, and is therefore entitled to deductions for                  
          various expenses in excess of the amounts stipulated.                       
               In so doing, we find that in addition to the amounts                   
          stipulated by the parties, petitioner is entitled to deductions             
          for the following expenses in the following amounts:  (1) Travel            








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