Pennel Phlander Irwin - Page 3

                                                 - 3 -                                                    
            Petitioner received a B.A. degree in history from California                                  
            State University at Sacramento.   He has written five unpublished                             
            novels, including: Great Woods Poppy; Trappers; Forever Three                                 
            Friday; Positively People; and Atla One, the first of a trilogy.                              
                  With respect to his activities as a "self-employed                                      
            writer/editor/educator", petitioner reported income and claimed                               
            expenses on Schedules C as follows:3                                                          
            Expenses                1990       1991       1992                                            
            Car and truck expenses             $4,187     $5,633     $10,228                              
            Insurance                           2,549      2,917       2,597                              
            Legal and professional services       139        100         545                              
            Office expense                        157      1,498       1,647                              
            Vehicle lease                       2,621      2,639       2,658                              
            Lease of other business property    3,222      2,925       3,130                              
            Repairs and maintenance                48        582         629                              
            Taxes and licenses                    445        535         527                              
            Travel, meals, and entertainment    1,892        738       1,833                              
            Utilities                           1,393      2,263       1,702                              
            Postage                                75        151         211                              
            Research                            9,455     10,237       4,366                              
            Writing experimentation                67        255         171                              
            Telephone                             784        910         804                              
                                                                                                         
            Total expenses                     27,034     31,383      31,048                              
            Gross income                        2,356      11,421       3,419                             
            Net income/loss                      (24,678)   (29,962)    (27,629)                          
                        1  Petitioner now concedes that this amount                                       
                  constituted gambling income, unrelated to his writing                                   
                  activities.  See supra note 2.                                                          

            3  The items and amounts listed are taken from petitioner's                                   
            amended returns (Forms 1040X) for the years 1990, 1991, and 1992.                             
            On the amended returns, petitioner claimed larger deductions than                             
            claimed on his original returns.  The notice of deficiency                                    
            specifically disallows the amounts claimed on both the original                               
            and the amended returns.                                                                      





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