John Shackelford Fairbanks - Page 3

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               During 1993, petitioner obtained a subcontracting consultant           
          job with TV Comm., Inc.  Although petitioner earned $5,400 as a             
          consultant in 1993 and reported this amount as gross receipts on            
          Schedule C, he also reported a net loss of $7,016 for 1993.                 
          During 1993, petitioner attempted to find additional clients but            
          was unsuccessful.                                                           
               In 1993, petitioner was employed as a full-time engineer at            
          Pacific Communication Sciences, Inc. (PCSI), working between 45             
          and 55 hours per week.                                                      
               Petitioner enrolled in graduate engineering courses at the             
          University of California-San Diego (UCSD), which were paid for by           
          PCSI.  Petitioner attended a graduate course at UCSD in the fall            
          of 1995 and attended an additional two or three courses in                  
          electrical engineering per semester in 1996.  Petitioner                    
          continued to work full time at PCSI until March 1996, when he was           
          laid off.  Petitioner enrolled full time in UCSD's doctoral                 
          program in 1997.                                                            
               Petitioner generated no income for his consulting activity             
          for the 1994, 1995, and 1996 tax years.  Petitioner was unable to           
          provide consulting services in either 1994 or 1995 because of the           
          long hours he worked at PCSI.  Even though petitioner worked full           
          time, he attempted to find clients that he could accommodate                
          taking into account his busy work schedule.  He was unsuccessful.           
               Petitioner reported no gross receipts from consulting                  

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