Dieter Stussy - Page 2

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               2.  Whether petitioner may deduct charitable contributions             
          claimed for expenditures made to his personal residence which               
          were allocable to space used exclusively by a section 501(c)(3)             
          organization named the Jan Stussy Foundation (Foundation).  We              
          hold he may not.                                                            
               3.  Whether petitioner may deduct at the standard mileage              
          rate his automobile expenses connected to the determination of              
          his personal income tax liability.  We hold he may.                         
               Unless otherwise indicated, section references are to the              
          Internal Revenue Code in effect for the years in issue.  Rule               
          references are to the Tax Court Rules of Practice and Procedure.            
          Dollar amounts are rounded.                                                 
                                  FINDINGS OF FACT                                    
               Some facts were stipulated.  The stipulated facts and the              
          accompanying exhibits are incorporated herein by this reference.            
          We find the stipulated facts accordingly.  Petitioner resided in            
          Los Angeles, California, when his petition was filed.                       
               During 1998, petitioner resided in a single family residence           
          (residence).  The residence measured 2,085 square feet and was              
          titled in the name of the Stussy Family Trust (Trust).                      
          Petitioner’s father, Jan Stussy (Dean Stussy), was the Trust’s              
          beneficial owner up until his death on July 31, 1990.  Dean                 
          Stussy was an active professional painter, and he was the Dean of           

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