Jeffrey Tamms - Page 6




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          then, JJT has reported net profits every year, as summarized in             
          this table:2                                                                
                                   Cost of                       Net Profit           
          Year      Receipts       Goods Sold     Expenses         or Loss            
          1988      $7,566         $5,149         $4,091         ($1,674)             
          1989      4,250          6,141          1,649          (3,540)              
          1990      6,060          9,188          2,081          (5,209)              
          1991      6,135          5,801          6,621          (6,287)              
          1992      7,805          6,109          4,802          (3,106)              
          1993      6,060          5,677          9,389          (9,006)              
          1994      7,019          5,493          12,051         (10,525)             
          1995      7,124          -0-            7,016          108                  
          1996      13,470         -0-            12,294         1,176                
          1997      14,426         -0-            13,200         1,226                
          1998      13,075         -0-            11,936         1,139                

               For the years in issue, JJT’s gross revenues were                      
          attributable to PSI and other sources (principally photography              
          exhibitions) as follows:                                                    
                              Gross Income        Gross Income                        
               Year             from PSI          from Other Sources                  
               1993           $6,060                   --                             
               1994           6,060               $959                                
               1995           2,460                    4,664                          
          For taxable years 1996 through 1998, producing photography                  
          exhibitions was the sole source of revenue for JJT.                         
               For the years in issue, petitioner claimed the following               
          costs of goods sold and deductions on his Schedules C, Profit or            
          Loss From Business (Sole Proprietorship) (Schedule C):                      



               2 The record does not indicate the amount of JJT’s losses or           
          other relevant tax information for years before 1988.                       





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