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Petitioner's Automobile Repair Activity
During 1984, petitioner was certified by the Federal Avia-
tion Administration as qualified to exercise the privileges of
mechanic for airframes and powerplants. On June 30, 1985,
petitioner was certified as competent by the National Institute
for Automotive Service Excellence (NIASE) in the service areas of
"engine repair", "front end", and "brakes". Petitioner allowed
his NIASE certification (1) in the service areas of "front end"
and "brakes" to expire in July 1989 and (2) in the service area
of "engine repair" to expire in July 1990.
Petitioner repaired cars in a garage located at his resi-
dence (automobile repair activity) for an undisclosed number of
years before 1993, the year at issue, as well as during that year
and 1994 and 1995. Prior to 1992, petitioner repaired automo-
biles for Leon Goldberg (Mr. Goldberg), his brother's father-in-
law, but he did not charge Mr. Goldberg for that work. Beginning
in 1992, petitioner informed Mr. Goldberg that he intended to
begin charging him for any automobile repair work that he did for
him at the rate of between $20 and $25 an hour for labor. During
1992 and 1993, petitioner repaired two cars for Mr. Goldberg for
which he billed him for his labor, although Mr. Goldberg usually
purchased any parts that petitioner needed in order to make those
repairs. Petitioner also did repair work during 1992 and 1993 on
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