Richard A. Stasewich - Page 2

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                                               Penalty, I.R.C.                        
                         Year    Deficiency      Sec. 6662(a)                         
                         1992     $3,998           $800.00                            
                         1993     2,860            572.00                             
                         1994     4,852            970.00                             
                         1995     3,064            612.80                             
          The issues for decision are whether petitioner’s artist activity            
          was not engaged in for profit within the meaning of section                 
          183(c) and whether petitioner is liable for accuracy-related                
          penalties pursuant to section 6662(a).                                      
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue.                 
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
               Richard A. Stasewich (petitioner) resided in Chicago,                  
          Illinois, at the time he filed his petition.  Petitioner attended           
          Northern Illinois University between 1971 and 1977, majoring in             
          art and minoring in accounting, but he did not graduate.  In                
          1978, petitioner was registered as a certified public accountant            
          by the University of Illinois, and, in 1983, he was licenced as a           
          public accountant by the State of Illinois.  Between 1978 and               
          1984, petitioner was employed in various positions utilizing his            
          accounting background.                                                      
               During the years in issue, petitioner operated both his                
          accounting and artist activities out of the same building, where            
          he also resided.  Beginning in 1984, petitioner treated his                 

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