Frank K. B. Wheeler - Page 13

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          advertise because he already had as much business as he could               
          handle himself; he did not want his videotape activity to become            
          “a big company.”                                                            
               Petitioner reported the income and expenses from his                   
          videotape activity on Schedule C from at least 1985 through 1995.           
          His videotape activity has generated losses every year since                
          inception.  Petitioner used the losses to offset his income.                
          That income has included his Navy pension, dividend income,                 
          interest income, capital gains, and Social Security benefits.               
          Table 6 shows petitioner’s adjusted gross income (before the                
          Schedule C loss), Schedule C gross receipts, Schedule C gross               
          income, Schedule C expenses, the Schedule C losses that he used             
          to offset his income, and adjusted gross income after Schedule C            
          loss.                                                                       

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