-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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