Karen L. Thorpe - Page 4

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          (wholesale activity), respectively.  In operating her wholesale             
          activity, petitioner purchased merchandise including T-shirts,              
          sweatshirts, and apparel accessories that she sold through mail             
          order advertisements and in person as a street vendor.  On                  
          separate Schedules C for 1993 and 1994, petitioner listed her               
          second activity as "banking institutions" and "financial                    
          consultant" (consulting activity), respectively.  In operating              
          her consulting activity, petitioner did financial consulting work           
          for both private banking institutions and Government agencies.              
               On her Schedules C for 1993 and 1994, petitioner reported              
          the following items of income and expenses related to her                   
          wholesale and consulting activities:                                        

          Wholesale            Consulting                                             
          Description                 1993       1994       1993      1994            
          Income:                                                                     
          Gross receipts or sales:  $2,000        $0     $17,667    $22,738           
          Cost of goods sold:                                                         
          Beginning inventory     (2,450)    (1,392)         0          0             
          Purchases               (4,700)    (1,613)         0          0             
          Ending inventory         1,392        150          0          0             
          (5,758)    (2,855)         0          0                                     
          Gross income:               (3,758)    (2,855)    17,667     22,738         
          Expenses:                                                                   
          Advertising                  575        326          0          0           
          Car & truck                4,634      1,363      1,372      5,481           
          Depreciation               1,785          0          0      1,288           
          Insurance                    578        200          0          0           
          Other interest               942          0          0          0           





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