Peter Spuler, Jr. - Page 5

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          1995 and 1996, petitioner, as a representative of SEC,                      
          contributed his services as a consulting engineer to nonprofit              
          organizations such as Christian Fellowship Ministries.  Neither             
          SEC nor petitioner billed or received any money for such                    
          services.  SEC did not receive taxable income during the years in           
          issue, nor did SEC pay petitioner any sums as either salary or              
          self-employment income during the years in issue.                           
               Petitioner maintained an account at Charles Schwab titled in           
          his name “UTA Charles Schwab & Co Inc, SEP-IRA DTD 11/20/93".               
          Contributions were made to the account in the amounts of $27,500            
          for 1995 and $30,000 for 1996.  Petitioner also paid $3,079 and             
          $4,570 for self-employed health insurance for 1995 and 1996.                
               Petitioner’s father, Peter J. Spuler, Sr. (Mr. Spuler), died           
          in 1995.  During that year petitioner received a distribution in            
          the amount of $10,906 from Mr. Spuler’s estate representing                 
          petitioner’s share of an IRA owned by Mr. Spuler and held by the            
          South Jersey S&L Association.  The record is unclear as to                  
          whether petitioner was listed as a beneficiary of the IRA and/or            
          whether the distribution was paid directly to petitioner or                 
          passed through the estate.  Mr. Spuler’s will provided that his             
          estate would be liable for all Federal, State, and other taxes              
          arising from the transfer of property under the will.                       
               Petitioner received automatic extensions to file his 1995              
          and 1996 Federal income tax returns.  The due date of the 1995              

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