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allowed by respondent; (3) whether, as respondent determined for
the years 1992 and 1993 through an indirect method, petitioner
received unreported gross income from two trade or business
activities petitioner was engaged in; (4) whether an S
corporation in which petitioner was a shareholder is entitled to
an expense deduction under section 179 for the year 1993 in an
amount greater than that allowed by respondent; (5) whether
petitioner is entitled, for her 1988, 1989, and 1990 tax years,
to deductions for net operating loss carrybacks from her 1991,
1992, and 1993 tax years; and (6) whether petitioner is liable
for the additions to tax and penalties shown above.
The facts, as stipulated by the parties, along with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petitions were filed, petitioner's
legal residence was Oakland, California.
Petitioner had been employed by the U.S. Postal Service for
several years. In the course of her employment, she sustained
injuries that ultimately resulted in her retirement from the
Postal Service on disability. Thereafter, petitioner became
engaged in several business activities along with three of her
sisters, Barbara J. Wilson, Faye W. Oatis, and Marian Wilson.
These activities are briefly described as follows:
(1) Klyce Day Care. This was a child day care service that
petitioner began in 1979. It was a general partnership
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