Richard A. Stasewich - Page 4

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          journal, and receipts for expenses.  Petitioner had a Certificate           
          of Registration in the State of Illinois that authorized him to             
          engage in the business of selling tangible personal property at             
          retail in Illinois.  For 1992 through 1994, petitioner filed                
          Forms ST-1, Sales and Use Tax Returns, with the Illinois                    
          Department of Revenue.  In 1995, petitioner completed Forms W-2,            
          Wage and Tax Statements, for the art students that he employed.             
          Petitioner neither kept records of a budget or financial                    
          projections for his artist activity nor kept a record of the                
          costs that he might incur in attempting to develop his artist               
               Prior to 1992, petitioner decided to create a commercially             
          viable product from his nude drawings.  Petitioner tried fashion            
          illustrations and spent a lot of money on materials and props,              
          but he never secured a large client and never earned anything               
          from it.                                                                    
               On or around 1992, petitioner’s artist activities changed              
          from nude drawings and fashion illustrations to portraitures and            
          installation art displays.  At a cost of about $1,200, he placed            
          two advertisements in his local newspaper on December 11 and 18,            
          1992, to solicit work as a commissioned artist of portraits.                
          Petitioner painted two portraitures between 1992 and 1995 that              
          generated about $850 in revenue.  During 1992 to 1995, petitioner           
          created four displays of installation art (consisting of peppers,           
          dolls, pumpkins, and cucumbers) that were displayed in front of             

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