Rilwan Adisa Salami - Page 2

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               Respondent determined deficiencies in petitioner's Federal             
          income taxes for 1992 and 1993 in the amounts of $3,857 and                 
          $1,877, respectively, and accuracy-related penalties pursuant to            
          section 6662(a) in the amounts of $771 and $329, respectively.              
               The issues for decision are:  (1)  Whether petitioner had              
          unreported Schedule C gross receipts in the amounts determined by           
          respondent; (2) whether petitioner is entitled to Schedule C                
          business expense deductions in excess of the amounts allowed by             
          respondent; (3) whether petitioner's net earnings from self-                
          employment are excludable from self-employment income because he            
          is a nonresident alien; and (4) whether petitioner is liable for            
          the section 6662(a) accuracy-related penalty.                               
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioner resided in Chicago,                   
          Illinois, on the date the petition was filed in this case.                  
               Petitioner came to the United States in 1986.  He formerly             
          worked as a security guard in California.  Petitioner moved to              
          Chicago in January 1992 and began working as a taxicab driver.              
               Petitioner shared a friend's taxicab from January 1992 to              
          April 1992.  The friend allowed petitioner to drive his 1990                
          Chevrolet Caprice at night.  From April 1992 to June 1992,                  
          petitioner drove a car that he leased from Yellow Cab Company.              
          In July 1992, petitioner purchased his friend's 1990 Chevrolet              
          Caprice, which he drove until December 28, 1992.  From December             

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