Paul F. Dickie - Page 3




                                        - 3 -                                         

               During 1994 and 1995, petitioner was employed full time as a           
          quality engineer with Illbruck, Inc. (Illbruck).  Petitioner's              
          1994 and 1995 Forms W-2, Wage and Tax Statement, from Illbruck,             
          showed that petitioner earned wages in the amounts of $52,169.45            
          and $49,046.00, respectively.  On petitioner's 1994 Form 1040,              
          U.S. Individual Income Tax Return, petitioner reported on line 7,           
          wages, salaries, tips, etc. in the amount of $52,169.  Sherry's             
          1995 Form W-2 from Speak The Word Church and World Outreach                 
          showed that she earned $29,355.28.  On petitioners' 1995 Form               
          1040, U.S. Individual Income Tax Return, petitioners reported on            
          line 7, wages, salaries, tips, etc. in the amount of $78,401.               
               During 1994, petitioner was married to Saundra.  In late               
          February or early March 1994, after about 18 months in remission,           
          Saundra's breast cancer recurred.  Petitioner and Saundra sought            
          alternative medical therapy.  In 1994, petitioner and Saundra               
          paid Natural Wellness $3,018 for consultation and dietary                   
          "supplements".  Natural Wellness was operated by Frank Charles.             
          Saundra died in August 1994.                                                
               Petitioner also is a musician.  He began taking music                  
          lessons when he was about 8 years old.  Petitioner plays the                
          trumpet, keyboards, and guitar.  During the taxable years at                
          issue, petitioner played electric and acoustic guitars with the             
          choir of Speak the Word Church and World Outreach (the Church)              
          located in Golden Valley, Minnesota.  The choir, known as                   





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