Scott C. and Patricia A. Simpson - Page 3

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          also employed as a technical specialist for American Stores, a              
          chain of grocery stores.                                                    
               Petitioners filed their 1992 and 1993 Federal income tax               
          returns in a timely manner.  On the returns, petitioners attached           
          Schedule C (Profit or Loss From Business) and reported on those             
          schedules gross income of $321 for 1992 and $7,348 for 1993.                
          Petitioners also reported, on those schedules, expenses relating            
          to advertising, car and truck expenses, insurance, interest,                
          legal and professional services, office expenses, rent or lease             
          payments, repairs and maintenance, supplies, taxes and licenses,            
          travel, meals and entertainment, and utilities.  These expenses             
          totaled $42,600 for 1992 and $63,733 for 1993.                              
               Petitioners deducted supply expenses of $10,994 for 1992 and           
          $16,697 for 1993.  These expenses included:  $2,159.90 for a                
          wide-screen television and an extended warranty; $1,975 for a               
          satellite television system; $344.68 for a television sound                 
          system; $658 for a video cassette recorder (VCR) and an extended            
          warranty; $848.95 for a cross-country ski machine; over $7,000              
          for groceries; and numerous payments to wineries.                           
               Petitioners deducted legal and professional service expenses           
          of $5,018 for 1992 and $9,048 for 1993.  These expenses included            
          the cost of several home improvements (e.g., landscaping, a deck,           
          and a fence around a swimming pool) and the cost of items                   
          relating to the satellite television system, a water purifier,              
          and pest control.                                                           




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