Earl L. Miller and Nancy B. Miller - Page 2

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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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