Melissa S. Spranger - Page 3




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          Federal income tax returns.  Petitioner and her former husband              
          separated in 1993 and were divorced in 1994.                                
               From 1989 through the date of trial, petitioner never                  
          realized or reported on a Federal income tax return a net profit            
          from the activity.  The income and expenses with respect to the             
          activity reported on petitioner's Federal income tax returns from           
          1993 through 1996, inclusive, are summarized in the following               
          table:                                                                      
               Year           Income         Expenses       Net Loss                  
               1993           $ 525          $29,142        $28,617                   
               1994           375            19,111         18,736                    
               1995           350       14,670              14,320                    
               1996      250                 7,104          6,854                     
                                                                                     
               On her 1993 Schedule C petitioner reported the following               
          items:                                                                      

               Income                             $525                                
               Expenses                                                               
                    Advertising         $  891                                        
                    Depreciation        7,903                                         
                    Insurance           1,932                                         
                    Interest            4,196                                         
                    Repairs             2,431                                         
                    Supplies            3,616                                         
                    Tax                 254                                           
                    Travel, etc         5,071                                         
                    Other               2,848     29,142                              
               Net loss                           28,617                              










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