Fabian Vaksman - Page 4




                                        - 4 -                                         
          stipend.4                                                                   
               During 1997, petitioner rented a one-bedroom apartment.                
          Petitioner had a land-line telephone in his apartment, and he               
          also had a cellular telephone.                                              
               During 1997, petitioner owned a 1994 Pontiac automobile.               
          Petitioner did not maintain any log or other record regarding the           
          use of his vehicle.                                                         
          Petitioner’s Income Tax Return                                              
               Petitioner filed a Federal income tax return for 1997,                 
          utilizing Form 1040PC, Format U.S. Individual Income Tax Return.5           
          Petitioner “attached” to his return several forms and schedules,            
          including the following: Schedule C, Profit or Loss From                    
          Business; Form 4562, Depreciation and Amortization; and Form                
          8829, Expenses for Business Use of Your Home.                               


               4 Petitioner testified that his work as a research assistant           
          in Russian medieval history “couldn’t really be reconciled with             
          [my] dissertation because I actually passed my orals in US                  
          history”.                                                                   
               5  A Form 1040PC return is a computerized return prepared              
          using a personal computer; it is the forerunner of electronic               
          filing.  IRS Publication 17 (1997 ed.) describes a Form 1040PC              
          return as follows:                                                          
                    The computer prints the return in a three-column                  
               “answer sheet” format.  It prints line numbers and                     
               dollar amounts (and/or supporting explanations if                      
               necessary) only for lines on which you made an entry.                  
               Supporting tax forms and schedules are also printed in                 
               this format.  As a result, an 11-page conventional                     
               return requiring forms and schedules can be printed as                 
               a two-page 1040PC return.                                              





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