Wayne and June Ellen Hairston - Page 3

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               (3) whether petitioners are entitled to deduct on their                
          Schedule C for the taxable years 1988, 1989, and 1990, various              
          expenses in excess of those allowed by respondent;                          
               (4) whether petitioners are liable for the addition to tax             
          for negligence under section 6653(a)(1) for 1988;                           
               (5) whether petitioners are liable for an accuracy-related             
          penalty for negligence under section 6662(a) for 1989 and 1990;             
          and                                                                         
               (6) whether petitioners are liable for an addition to tax              
          for late filing under section 6651(a)(1) for 1990.                          
               For simplicity and clarity, we will first set forth the                
          relevant background facts and general legal principles; we will             
          then combine additional findings of fact and opinion for each               
          issue.                                                                      
          Background Facts                                                            
               Some of the facts have been stipulated, and they are so                
          found.  Petitioners resided in Dothan, Alabama, at the time that            
          their petition was filed with the Court.                                    
               Petitioner Wayne Hairston (petitioner) received both a                 
          bachelor's degree in psychology and a graduate degree in                    
          Christian counseling from Liberty University.  Petitioner has               
          also completed undergraduate religion courses and graduate                  
          theology courses.  In addition to his formal education,                     
          petitioner is an ordained minister.  Petitioner was ordained by             
          the Body of Christ Church on May 17, 1987.  The Body of Christ              




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