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Background
During the period 1987 through 1994, petitioner sold
insurance for United American Insurance Company (hereinafter
United). Petitioner received $1,098 in compensation from United
in 1994. Upon his resignation from United in 1994, petitioner
received a distribution in the amount of $1,422 from his
retirement fund. Petitioner used this money to establish a mail-
order business, and was issued a "Sales and Use Tax Certificate
of Registration" from the Government of the District of Columbia
on September 13, 1995. Also during 1994 and subsequent years,
petitioner studied law through Kensington University College of
Law, an unaccredited law school in California. Petitioner paid
$650 to the State Bar of California for law school examination
fees in 1994 and $300 for law school examination fees in 1995.
Petitioner attached two Schedules C to each of his 1994 and
1995 Federal income tax returns. The Schedules C reflect the
following:
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