Earl L. Miller and Nancy B. Miller - Page 6

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            During 1993, petitioner did not reimburse her personal account                              
            with funds from her writing activity account.  Petitioners                                  
            consulted with an accountant in structuring their records and in                            
            categorizing various expenses for Federal income tax purposes.                              
                  Petitioner's father died in 1993.  Petitioner and her sister                          
            were the sole beneficiaries of their father's estate, which was                             
            worth about $1.5 million.                                                                   
                  The following items of income were reported on petitioners'                           
            Federal income tax returns for the years in issue:                                          
                                                        1993              1994                          
                   Wages                            $57,466.00        $50,032.38                        
                   Interest income                   37,185.93          45,998.54                       
                   (incl. tax-exempt int.)                                                              
                   Dividend income                   14,748.32           6,516.50                       
                   Capital gain (loss)               17,307.15          (3,000.00)                      
                   Social Security benefits            6,187.20          6,349.20                       

                  Petitioners began treating her writing activity as a trade                            
            or business in 1990.  The income and expenses attributable to                               
            that activity from that year on were reported on a Schedule C.                              
            As of the date of trial, petitioner's writing activity had not                              
            resulted in a profit for any year, as reflected in the following                            
            table:                                                                                      
                                    Year            Net Loss                                            
                                    1990               $6,463.28                                        
                                    1991                7,732.60                                        
                                    1992                7,822.23                                        
                                    1993               17,064.66                                        
                                    1994               13,823.70                                        
                                    1995               11,047.00                                        
                                    Total              63,953.47                                        



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