Wale O. Osijo - Page 10

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          by petitioner as part of his presentation of the sequence of                
          events pertaining to his litigation travails.  The contents of              
          that document are disputed by petitioner and are pure hearsay.              
          Ms. Michell was not called as a witness to support its contents,            
          and it does not lend persuasive support to respondent’s                     
          determination.  Thus, in view of petitioner’s credible denial               
          that he received such interest, we hold that petitioner did not             
          receive any taxable interest income from his attorney or any                
          trust in 1993.                                                              
               Respondent also determined for the 1993 year that petitioner           
          earned Schedule C income of $3,750 resulting from the preparation           
          of 25 tax returns at $150 per return.  We conclude, based upon              
          petitioner’s testimony, that petitioner had $2,000 of Schedule C            
          income, resulting from the preparation of 10 tax returns at $200            
          apiece.  Petitioner has failed to present any books and records             
          of his 1993 tax preparation business.  Accordingly, he has failed           
          to prove which of his clients, if any, failed to pay his fee.  In           
          addition, petitioner claims that he had legitimate business                 
          expenses to offset that income.  However, he has failed to                  
          substantiate any business expenses.  While our conclusions herein           
          result in no taxable income for petitioner for 1993 (as                     
          petitioner’s income for the year is less than the combined amount           
          of his personal exemption and standard deduction), petitioner               

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