James P. and Marilyn S. Cashman - Page 2




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          self-employment tax of $1,835 and its corresponding $918                    
          deduction.  Respondent filed a Motion to Dismiss For Lack of                
          Prosecution With Respect To Petitioner Marilyn S. Cashman, which            
          was granted.  Pursuant to this Court's Order, we held that                  
          Marilyn S. Cashman is liable for a deficiency in Federal income             
          tax for 1995 in a reduced amount.  After concessions, this Court            
          must decide whether James Cashman (petitioner) is entitled to               
          deduct $12,988 of claimed Schedule C, Profit or Loss From                   
          Business, expenses in 1995.  If petitioner is not entitled to               
          deduct this amount, both petitioners will be liable for a                   
          deficiency in Federal income tax for 1995 in the reduced amount             
          of $1,950.                                                                  
               Some of the facts in this case have been stipulated and are            
          so found.  Petitioners resided in Stillwater, Minnesota, at the             
          time they filed their petition.                                             
               In 1991, petitioner incorporated World Youth Foundation,               
          Inc., under the laws of Minnesota.  The corporation's name was              
          changed to I.D. Solutions, Inc., in 1992.  The corporation's name           
          was again changed in 1994 to I.D. Club, Inc. (I.D. Club).  In               
          1997, I.D. Club was involuntary dissolved by the Minnesota                  
          Secretary of State.                                                         
               I.D. Club was a private, 24-hour emergency information relay           
          service where a family could register children or any other                 
          individual.  I.D. Club would maintain information on each                   





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