Joe Nathan Bryant, Jr. - Page 2

                                        - 2 -                                         
          Year     Deficiency     Sec. 6662(a)                                        
          1992       $8,376          $1,675                                           
          1993        8,137           1,627                                           
               All section references are to the Internal Revenue Code in             
          effect for the years in issue.  All Rule references are to the              
          Tax Court Rules of Practice and Procedure.                                  
               At the time the petition herein was filed, petitioner was a            
          resident of Birmingham, Alabama.  He filed his income tax returns           
          for the years 1992 and 1993 on the basis of married filing                  
          separately.  In the years in issue, petitioner was employed as a            
          policeman for the Fairfield Police Department.  He also provided            
          private security service and was a member of the Coast Guard                
          Reserve during these years.                                                 
               At trial herein, petitioner appeared on behalf of himself.             
          Although he testified, he produced no other witnesses, and no               
          documentary evidence of any sort was offered in support of his              
          position.  He admitted at trial that he failed to substantiate              
          any of the business expenses claimed on Schedule C of his 1992              
          and 1993 tax returns, and he also admitted that he did not                  
          substantiate any of the claimed deductions on Schedule A of his             
          1992 and 1993 tax returns.                                                  
               The adjustments made by respondent to petitioner's taxable             
          returns were as follows:                                                    

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