James H. Shelton, Deceased, and Eve Shelton - Page 3

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          (1) Marketing activities relating to a book that he authored and                   
          published in a previous year; and (2) private educational                          
          seminars that he conducted that were not connected with his                        
          employment at Sierra.                                                              
                Prior to 1992, petitioner wrote and published a book, at his                 
          own expense.  On January 6, 1992, petitioner paid a publishing                     
          company $3,070.50 to have 1,035 copies of his book printed.                        
          Petitioner was charged $3.003 per copy for the first 1,000 copies                  
          and $2.250 for the next 30 copies.  He received 5 free copies.                     
                During 1992, petitioners traveled to several cities,                         
          including the following:  Phoenix, Arizona; Minneapolis,                           
          Minnesota; Reserve, New Mexico; and Los Angeles, California.                       
          Typically, there were large shopping malls in these cities and                     
          located in these malls were retail bookstores.  Without making                     
          any advance arrangements or appointments, petitioner visited                       
          several of the bookstores in the city where he happened to be in                   
          an attempt to market his book.  Usually he left a sample copy of                   
          the book with the manager or other employee of the bookstore.                      
          Petitioner did not maintain a log or other record to indicate                      
          what bookstores he visited or the number of sample copies of his                   
          book that he gave out during 1992.  During these trips                             
          petitioners visited with relatives who were living in the area.                    
                In October of 1992, petitioner sold $124 worth of books.  He                 
          included this amount in the amount of gross receipts he reported                   






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