Hugh T. Brown, Jr., and Kristi L. Brown - Page 7




                                        - 6 -                                         
               Depreciation and sec. 179         3,901          2,422                 
               Interest                           317             -0-                 
               Legal and professional services    500             100                 
          Office expense                          591             893                 
               Repairs and maintenance            565             177                 
          Supplies                           1,940              1,230                 
               Travel                             -0-             220                 
               Meals and entertainment [50%]      604             424                 
               Utilities                          788           1,024                 
               Other expenses1                   2,296          2,515                 
               Total expenses                15,219            214,276                
               Total net losses              (14,993)       (213,876)                 
                    1The “Other expenses” claimed for 1996 were:                      
                    Cont. ed., books, and journals               $692                 
                    Dues and subscriptions                       72                   
                    Licenses and permits                    145                       
                    Promotional items                            487                  
                    Telephone                                    737                  
                    Uniforms and laundry                         163                  
                    The “Other expenses” claimed for 1997 were:                       
                    Dues and publications                        $285                 
                    Miscellaneous                                50                   
                    Parking                                      22                   
                    Postage, etc.                                445                  
                    Printing                                     66                   
                    Tools                                        560                  
                    Sales and marketing                          665                  
                    Promotional efforts                          422                  
                    2Petitioners actually reported total expenses of                  
               $14,296 and total net losses of $13,896, and the slight                
               mathematical errors have been corrected.                               
               Respondent concedes that petitioners incurred and paid all             
          of the expenses listed on their Schedules C for Brown Enterprises           
          during the years in issue.                                                  
               Respondent disallowed the Schedule C losses on the ground              
          that petitioners did not establish that their mining activity               






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