Charles E. King - Page 2

            office under section 280A; (2) whether petitioner is entitled to                              
            claim a deduction for health insurance premiums; and (3) whether                              
            petitioner is entitled to a deduction for a contribution to an                                
            individual retirement account (IRA).                                                          
                  Some of the facts have been stipulated and are so found.                                
            The stipulation of facts and the exhibits received into evidence                              
            are incorporated herein by this reference.  Petitioner filed a                                
            timely joint Federal income tax return for 1990 with his wife,                                
            Betty W. King (Mrs. King), now deceased.  Petitioner resided in                               
            Holly Hills, Florida, at the time he filed his petition.                                      
                  In 1983, after petitioner retired from his position as a                                
            school administrator for Fairfax County, Virginia, he and Mrs.                                
            King moved to Holly Hills, Florida, and started a yacht charter                               
            and brokerage business under the name of King International.                                  
            King International was a sole proprietorship with its business                                
            office located in petitioner's home at 1402 Riverside Drive,                                  
            Holly Hills, Florida.  Petitioner ran the daily operations, and                               
            Mrs. King handled the financial end of the business.                                          
                  During the year at issue, petitioner received pension income                            
            of $44,669.45 and interest income of $12,111.23, a portion of                                 
            which he used to finance his business operations.  Petitioner                                 
            owned a West Mariner 39 yacht which he used to advertise his                                  
            brokerage activities and attract charter customers for King                                   
            International.  During 1990, petitioner was not employed, and,                                

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