Eugene Clark - Page 2

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               The issues in this case are:  (1) Whether petitioner is                
          entitled to a Schedule C, Profit and Loss From Business, car and            
          truck expense deduction beyond that which respondent allowed; (2)           
          whether petitioner is entitled to a Schedule C depreciation                 
          expense deduction beyond that which respondent allowed; and (3)             
          whether petitioner overstated Schedule C gross receipts.1  An               
          adjustment to the self-employment tax and deduction therefor is             
          computational and will be resolved by the Court’s holding on the            
          issues in this case.                                                        
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time the petition            
          was filed, petitioner resided in Owings Mills, Maryland.                    
               Petitioner has a doctorate in education.  During 1996,                 
          petitioner provided human resource consulting services through a            
          business entity known as E. Clark and Associates, a sole                    
          proprietorship.  Petitioner operated his business from his home.            
          Petitioner rendered services to governmental agencies.  These               
          agencies issued purchase orders to petitioner.  After completion            
          of the job an invoice was sent to the agency for payment.                   

          1    Petitioner raised an additional issue in his petition:                 
          Whether petitioner was entitled to Schedule A, Itemized                     
          Deductions, in lieu of the standard deduction.  This issue was              
          abandoned by petitioner at trial.                                           

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