Kathleen J. Kelly - Page 4

                                                  4                                                   
                  In early fall of the year in issue, petitioner participated                         
            in a festival held in Adams Morgan, an area of Washington, D.C.                           
            Petitioner had a booth for Too Close To Home where she handed out                         
            balloons imprinted with messages.  The record contains a receipt                          
            for a $300 cash deposit petitioner paid for the order of the                              
            imprinted balloons.                                                                       
                  During the year in issue, petitioner organized a Haitian                            
            tour for four people.  In November 1989, petitioner traveled to                           
            Haiti with the tour group.  Petitioner charged each individual                            
            $300 in addition to the cost of his or her airline ticket.                                
            Petitioner applied the $300 to the cost of room and board in                              
            Haiti, and she distributed the remaining amount to various                                
            charities that the group visited in Haiti.                                                
                  On December 3, 1989, petitioner organized and cohosted an                           
            art show for the benefit of the orphans of Haiti.  Petitioner                             
            estimated that the postcards announcing this event cost $800 to                           
            produce.                                                                                  
                  Petitioner's records of the expenses paid for Too Close To                          
            Home are virtually nonexistent.  Petitioner maintained a bank                             
            account in the name of Too Close To Home.  Petitioner did not                             
            keep any records detailing the purpose for which funds were                               
            expended.  The checking account records show that the following                           
            amounts were paid from this account in 1989.  In November, three                          
            checks totaling $2,043 to Omega Travel for plane tickets were                             
            paid.  Petitioner wrote a check to 69 Observatory Circle in the                           




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