St. Elmo H. Nauman, Jr. - Page 2

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          Federal income tax in the amount of $4,256 and an addition to tax           
          of $400 pursuant to section 6651(a)(1).                                     
               The issues for decision are:  (1) Whether petitioner was               
          engaged in a trade or business during 1993; if so (2) whether               
          petitioner substantiated certain expenses relating to the trade             
          or business; and (3) whether petitioner is liable for the                   
          delinquency addition to tax.                                                
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and they are so                
          found.  The stipulation of facts and the attached exhibits are              
          incorporated herein by this reference.  At the time he filed his            
          petition, petitioner resided in El Toro, California.                        
               During 1993, petitioner worked for the Immigration and                 
          Naturalization Service (INS) in the asylum office as one who                
          interviewed refugees who come to the United States.  Petitioner             
          also worked as a part-time professor at Chapman University                  
          (Chapman) teaching classes in philosophy and religion and as a              
          chaplain for the United States Navy (the Navy), lecturing and               
          performing religious services.  Petitioner is an ordained                   
          minister of the United Church of Christ and has been for the past           
          40 years.                                                                   
               Before 1993 and over the course of his career, petitioner              
          worked in many different capacities, including working as a                 
          professor at different colleges and universities, working on                





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