Sheriel L. Sexcius - Page 3

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          incorporated herein by this reference.  At the time the petition                   
          was filed, petitioner resided in Washington, D.C.                                  
                                     FINDINGS OF FACT                                        
                During 1989, petitioner was employed on a full-time basis as                 
          a teacher in the District of Columbia Public School System.                        
          Petitioner holds a bachelor of science degree and a master's                       
          degree, and is certified to teach biology at the senior high                       
          school level.  Petitioner is also a registered nurse and during                    
          the year in issue was employed on a part-time basis with                           
          Medlantic Long Term Care Corp. as a nurse on weekends and                          
          holidays.                                                                          
                Beginning in 1979 and continuing at least through 1991,                      
          petitioner engaged in a tutoring and counseling activity (the                      
          tutoring activity).  For the years 1979 through 1991, without                      
          data available for years 1981 and 1990, petitioner reported                        
          Schedule C gross receipts in the aggregate amount of $36,880, and                  
          other income on Schedule C in the aggregate amount of $6,275, and                  
          claimed total deductions of $172,868.55 that resulted in a loss                    
          for each year, and an aggregate loss in the amount of                              
          $129,713.55.  Petitioner provided her tutoring and counseling                      
          services primarily to individuals from low income, impoverished                    
          families.  Petitioner operated the activity in 1989 in a similar                   
          manner to its operation in prior years.  Thus, the general set up                  
          of the activity, the number of students tutored, the time she                      
          devoted to the activity, and various other policies and practices                  




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