Kenneth Miles and Michon Snow Tesar - Page 4

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          a substantial understatement of taxes in 1992 and 1993.  An                 
          increase in self-employment taxes for Mrs. Tesar is computational           
          and will be resolved by our decisions with respect to the second            
          and third issues.                                                           
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Petitioners resided in              
          Homewood, Illinois, at the time their petition was filed.                   
               During the years in issue, petitioner was employed as a                
          mathematics teacher at Homewood-Flossmoor Community High School             
          (referred to as the school).  Petitioner had been teaching there            
          since 1969.  Petitioner was also employed as a mathematics                  
          professor at Purdue University.                                             
               Sometime in 1982, a group of students approached petitioner            
          and asked if he would be willing to sponsor a club for students             
          interested in comic books and sequential art.  Petitioner agreed.           
          In addition to teaching various high school math classes,                   
          petitioner acted as the sponsor for a number of extracurricular             
          activities at the high school, including the chess club,                    
          "Mathletes" (the math club), the Star Trek club, and the comic              
          book club.  Petitioner's understanding was that he should sponsor           
          or participate in some type of student activity as an employee of           
          the school district.                                                        







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