Craig E. and Debbie A. Brown - Page 7

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               Rent/lease other business                                              
               property                  5,560                                        
               Repairs                   4,213                                        
               Supplies                    138                                        
               Travel                    1,562                                        
               Meals and entertainment     940                                        
               Utilities                 2,104                                        
               Wages                    15,100                                        
               Software                  5,755                                        
                                        48,393                                        
               A second Schedule C was attached to the amended return for             
          an activity described as Minister of Music. On this Schedule C              
          petitioner reported gross receipts of $6,505,2  and claimed the             
          following expenses:                                                         
               Expense                    Amount claimed                              
               Car and truck                      $1,513                              
               Commissions                        16,638                              
               Depreciation                          792                              
               Office expense                        711                              
               Rent or lease other business                                           
               equipment                           1,174                              
               Supplies                            2,808                              
               Taxes                                 537                              
               Travel                              4,994                              
               Meals and entertainment             1,208                              
               Postage, telephone, special robes                                      
               seminars, promotions, dues                                             
               and publications, licenses                                             
               and fees                         14,560                                
               44,935                                                                 
               The amended return did not include a Schedule A, and no                
          charitable contribution deduction was claimed thereon.                      
               On February 11, 1994, a notice of deficiency was issued to             
          petitioners based upon the original return. Respondent therein              


               2    The $6,505 represents income from petitioner-'s computer          
          consulting activity, and the total income reported on the two               
          Schedules C equals the gross income reported on the Schedule C              
          attached to the original return.                                            



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