Roger Steven Lewis - Page 3

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          Federal income tax and additions to tax under sections 6651(a)(1)           
          and (2) and 6654(a) in the respective amounts of $1,030.27,                 
          $618.16, and $246.68 for the 1997 tax year.                                 
               In two written stipulations, all of the issues have been               
          settled except the following: (1) The amount of petitioner's                
          basis, under section 1012, in stock of General Electric Co. (GE),           
          which petitioner sold or converted into cash during 1997; (2)               
          whether petitioner is entitled to a deduction under section                 
          162(a) for educational expenses; and (3) whether petitioner is              
          liable for the additions to tax.                                            
               As noted, some of the facts were stipulated.  Those facts,             
          with the annexed exhibits, are so found and are incorporated                
          herein by reference.  At the time the petition was filed,                   
          petitioner was a legal resident of Los Angeles, California.                 
               Petitioner did not file a Federal income tax return for                
          1997.  He engaged in several transactions that year in which                
          gains and losses were realized.  By stipulation, the gains or               
          losses from all but one of the transactions have been agreed to.            
          The unagreed transaction relates to an account petitioner                   
          maintained with GE that was generally referred to as a dividend             
          reinvestment plan.  Petitioner could (and did) contribute money             
          from time to time that was used to purchase stock in GE, and the            
          dividends from such stock were also used to purchase additional             
          GE stock.  Under the account plan, GE issued fractional shares if           

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