Vena Marilyn Wofford - Page 2

                                          2                                            
               Respondent determined deficiencies in, additions to, and a              
          penalty on petitioner's Federal income taxes as follows:                     
                                      Additions to Tax         Penalty                 
                              Sec.            Sec.      Sec.   Sec.                    
          Year      Deficiency   6651(a)(1) 6653(a)(1)   6654(a) 6662(a)               
          1988      $3,088         $408       $160      ---    N/A                     
          1989      5,760          1,393      N/A       ---   $1,152                   
          1990      7,721          1,930      N/A       $10    ---                     
          1991      6,880          1,720      N/A       397    ---                     
               After concessions,2 the issues for decision are:  (1)                   
          Whether petitioner is entitled to amortization deductions with               
          respect to certain intangible assets acquired in connection with             
          her business of being a Safeguard distributor; and (2) whether               
          petitioner is allowed to carry forward net operating losses                  
          sustained in taxable years 1988, 1989, and 1990.                             
               Some of the facts have been stipulated and are so found.                
          The stipulation of facts and the exhibits received into evidence             
          are incorporated herein by this reference.  Petitioner resided in            
          Dallas, Texas, at the time her petition was filed.                           
               Petitioner began working in the printing business in 1968 in            
          the Dallas-Fort Worth area of Texas.  She was employed in the                
          early 1970's as a salesperson and sales manager for a company                


          2    Petitioner concedes she is liable for the additions to tax              
          under sec. 6651(a)(1) for each taxable year in issue, and under              
          sec. 6654(a) for the taxable years 1990 and 1991.  Respondent                
          concedes the addition to tax under sec. 6653(a)(1) for 1988 and              
          the penalty under sec. 6662(a) for 1989.  Petitioner concedes she            
          is liable for self-employment tax on her taxable income as                   
          finally redetermined, and agrees to all of the arithmetical                  
          adjustments set forth in the notice of deficiency to the amount              
          of taxable income as finally redetermined.                                   




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