Dieter Stussy - Page 4

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               During 1998, petitioner paid the following expenses with               
          respect to the residence:  Insurance of $841, utilities of                  
          $1,729, homeowner’s association dues of $30, pest control of                
          $478, and repairs and maintenance of $1,704 (to replace a water             
          heater, to clear brush around the perimeter of the residence, and           
          to repair the furnace).  Petitioner allocated these expenses to             
          the Foundation using a percentage allocation and claimed a                  
          charitable contribution for the portion of the allocated                    
          expenses.  Petitioner did not receive any written acknowledgment            
          from the Foundation for any contributions purportedly made to the           
          Foundation by petitioner during 1998.  Nor did the Foundation               
          report its receipt of any contributions during 1998.                        
               During 1998, petitioner drove 275.1 miles for which he                 
          claims a miscellaneous itemized deduction at the standard mileage           
          rate.  The breakdown of these miles was:  165.5 miles for                   
          petitioner’s copying and filing of his personal Federal and State           
          income tax returns, 82.7 miles for petitioner’s meetings with               
          Internal Revenue Service personnel related to the examination of            
          his personal income tax returns, 14.5 miles for petitioner’s trip           
          to the Santa Monica law library, and 12.4 miles for petitioner’s            
          copying of a document entitled “Response to AG of IRS                       
          Investigation”.                                                             
               Petitioner’s 1998 Federal income tax return included 2                 
          Schedules C, Profit or Loss From Business.  One of these                    






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