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our disposition of the disputed issues, as well as the parties’
concessions regarding the Schedule C deductions described supra
in note 1.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. Petitioner resided in Houston, Texas, at the time that
his petition was filed with the Court.
During 1997, the taxable year in issue, petitioner held
himself out as a Russian translator.
On January 7, 1997, petitioner completed work on a contract
with Davis Petroleum Corp. of Houston, Texas (Davis Petroleum).3
Thereafter, from January 8, 1997, through the end of the year,
petitioner did not have any clients for whom he provided
translation services.
During 1997, petitioner was registered with the History
Department of the University of Houston, where he was pursuing a
doctoral degree. From May 1996 to February 1997, petitioner also
worked for the History Department as a research assistant,
focusing on Russian medieval history, for which he was paid a
2(...continued)
the Internal Revenue Code in effect for 1997, the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
3 On or about Jan. 27, 1997, Davis Petroleum paid
petitioner $19,244 for services rendered (and expenses incurred)
by petitioner from November 1996 through Jan. 7, 1997. Most, if
not all, of the amount paid relates to a trip to Kazakhstan.
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