Thomas B. Drummond - Page 17

                                       - 17 -                                         
          Net profit from                                                             
          Psychological                                                               
          Testing Services         7,372          34,930      104,371                 
          Schedule D capital gain       18,339       --          1,373                
          Schedule E loss for 1989                                                    
          and income for 1991           2,200         --         4,317                
          Schedule F loss     10,253              7,780       19,588                  
          Deduction for one-half of                                                   
          self-employment tax           --            176          558                
          Deduction for SEP                                                           
          contribution             20,000         16,912       26,00010               
               With respect to the $99,000 net profit that petitioner                 
          reported in Schedule C of his 1989 return relating to art sales,            
          petitioner informed Mr. McVeigh that he sold the drawing in                 
          question during 1989 at a gain.  Mr. McVeigh advised petitioner             
          that an important factor in characterizing that gain as self-               
          employment income was whether petitioner continued to purchase              
          and sell drawings in the future.  Petitioner informed Mr. McVeigh           
          that he intended to do so.  Based on the information that peti-             
          tioner provided to Mr. McVeigh, Mr. McVeigh concluded that the              
          gain from the sale of the drawing in question constituted self-             
          employment income, and not long-term capital gain, and that it              
          should be reported in a Schedule C of petitioner's 1989 return              
          relating to art sales.                                                      
               With respect to the automobile expense deductions claimed in           
          Schedules C of petitioner’s returns for the years at issue                  
          relating to Psychological Testing Services, petitioner gave Mr.             


          10  Although petitioner's 1991 return erroneously showed that               
          deduction as a deduction for "self-employed health insurance",              
          the parties agree that that deduction was for petitioner's 1991             
          SEP contribution.                                                           




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