Subhendu Das - Page 3

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               Trial of this case began on January 28, 1998.  At trial,               
          petitioner conceded the capital gain and loss issues for 1993 and           
          1995.  However, petitioner was not prepared to go forward with              
          his case concerning the claimed business expenses on Schedule C             
          for 1993 and 1994.  We continued the case to March 17, 1998, and            
          instructed petitioner to be prepared to present the facts of his            
          case along with the necessary documents and records.  Despite the           
          Court’s warning, petitioner was not prepared to discuss the                 
          substantiation issue, although some documents were stipulated               
          without explanation or elaboration.                                         
               Petitioner has a Ph.D. in electrical engineering.  In 1993,            
          he quit his job as an aerospace engineer in order to pursue his             
          invention of a computer-controlled nozzle sprinkler system                  
          (sprinkler system).  The sprinkler system consisted of a                    
          computer-driven rotating watering device for gardens and lawns.             
               Also in 1993, petitioner created a California corporation              
          called Computer Control Systems, Inc. (CCSI).  CCSI filed its               
          articles of incorporation on April 6, 1993.  Petitioner and his             
          wife were the only shareholders.  According to petitioner, CCSI’s           
          business was to produce the sprinkler system to sell to                     
          customers.  Petitioner was named the vice president of                      
          engineering, and his wife was named president of CCSI.  A                   
          separate checking account was opened in CCSI’s name.                        







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