Evelyn J. Glenn - Page 7




                                         - 6 -                                        
                On part IV of her 1995 Schedule C, petitioner claimed that            
           she drove her automobile 9,000 miles for business and 3,000 for            
           “other”, for a total of 12,000 miles for the year.                         
                Petitioner also filed an income tax return, Form 1040, for            
           1996.  On her return, petitioner reported total income in the              
           amount of negative $11,266, consisting of a “prior year NOL” in            
           the amount of $19,611 and net profit from her marketing                    
           business in the amount of $8,345.  Petitioner attached to her              
           return a Schedule C, reporting income and deducting expenses as            
           follows:                                                                   

                     Income                                                           
                     Gross receipts                  $102,513                         
                     Less: cost of goods sold         -58,350                         
                     Gross Profit                      44,163                         
                     Expenses                                                         
                     Advertising                        3,134                         
                     Car expenses                       5,301                         
                     Legal & professional               2,674                         
                     Office expense                     4,934                         
                     Pension & profit-sharing plans         8                         
                     Rent or lease (vehicle)            3,968                         
                     Rent (other business property)     4,800                         
                     Travel                             2,667                         
                     Utilities                          1,712                         
                     Other                                                            
                     Dues & memberships     $135                                      
                     Telephone             5,300                                      
                     Bank charges            584                                      
                     License                  66                                      
                     Continuing education    535     6,620                            
                     Total expenses                    35,818                         
                     Net profit                         8,345                         








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