Bruce K. Remy and Gail E. Remy - Page 7

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             determined tax deficiencies and penalties with respect to                
             the adjustment of petitioners' deductions for advertising,               
             bad debts, and rent expense.  The following explanation of               
             respondent's adjustment to petitioners' advertising expense              
             is provided in the notice:                                               

                  The deductions of $6,448.00, $16,535.00 and                         
                  $18,141.00 shown on your 1990, 1991 and 1992                        
                  returns, respectively, as Schedule C advertising                    
                  expense are reduced by $3,329.00, $15,600.00 and                    
                  $17,169.00, respectively, because it has not been                   
                  established that any amounts more than $3,119.00,                   
                  $935.00 and $972.00, respectively, were for                         
                  ordinary and necessary business expenses, or were                   
                  expended for the purpose designated.  Therefore,                    
                  your taxable income is increased $3,328.00,                         
                  $15,600.00 and $17,169.00, respectively.                            

             Prior to issuance of the notice of deficiency, petitioners               
             conceded liability for the portion of the proposed                       
             deficiencies attributable to the bad debts and rent expense              
             adjustments.  Petitioners did not concede liability for the              
             accuracy-related penalty under section 6662 with respect to              
             any of the adjustments.                                                  
                  Although he is highly educated, petitioner has had                  
             no formal training in tax law.  Since at least 1990,                     
             petitioner has researched income tax issues by reading the               
             Internal Revenue Code, accompanying regulations, case law,               
             and other tax materials such as tax guides.  Although                    
             petitioner has never sought formal advice from lawyers,                  






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