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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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