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Rule references are to the Tax Court Rules of Practice and
Procedure.
Respondent determined deficiencies in petitioners' 1993 and
1994 Federal income taxes in the amounts of $4,788 and $3,423,
respectively. The issue for decision is whether Nancy B.
Miller's writing activity constituted a trade or business during
the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners are husband and wife. They filed timely joint
Federal income tax returns for the years in issue. At the time
the petition was filed, petitioners resided in Akron, Ohio.
References to petitioner are to Nancy B. Miller.
Petitioner suffers from a condition known as Arnold-Chiari,
a neurological disorder which causes fatigue, lack of muscle
coordination, and blurred vision. She has been treated for these
symptoms, all of which are aggravated during times of stress,
since the 1970's. She was diagnosed with this affliction in 1989
and underwent brain surgery for the condition in 1994. She has
been receiving Social Security disability benefits as a result of
this illness since the early 1980's.
After graduating from the University of South Florida with a
bachelor's degree in psychology, petitioner was employed for
several years as a secretary and office manager for a travel
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