Richard A. Stasewich - Page 2

                                         -2-                                          
               Respondent determined deficiencies in, additions to, and an            
          accuracy-related penalty on petitioner's Federal income taxes as            
          follows:                                                                    
                                   Additions to Tax         Penalty                   
                                   Sec.      Sec.           Sec.    Sec.              
          Year      Deficiency     6651(a)   6653(a)(1)     6654   6662(a)            
          1988      $2,591         $586      $130           --     --                 
          1989      4,039          985       --             $15      --               
          1990      5,287          1,322     --             294      --               
          1991    7,586   --     --  --   $1,517                                      

               After concessions by the parties,2 the issues for decision             
          are:  (1) Whether petitioner's artist activity was "not engaged             
          in for profit" within the meaning of section 183(c); (2) whether            
          petitioner can substantiate claimed expenses; and (3) whether               
          petitioner is liable for the additions to tax and an accuracy-              
          related penalty as determined by respondent.  The resolution of             
          issue (1) will necessarily determine whether the income from                
          petitioner's artist activity is properly classified as gross                
          income derived from business or as miscellaneous income and                 
          short-term capital gain.                                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      




               2In the notice of deficiency, respondent disallowed                    
          deductions for auto, entertainment, and transportation                      
          expenditures for 1988 and also determined that petitioner had               
          unreported interest income for 1990.  Petitioner presented no               
          testimony or other evidence on these issues, and we deem them to            
          be conceded.                                                                




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