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1. Whether petitioner operated his direct marketing
activity for profit in 1997. We hold that he did.
2. Whether petitioner may deduct business expenses for 1997
in an amount greater than respondent conceded. We hold that he
may not.
3. Whether petitioner is liable for an addition to tax
under section 6651(a)(1) for failure to timely file his return
for 1997. We hold that he is.
Section references are to the Internal Revenue Code as
amended and in effect for 1997. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner resided in California City, California, when he
filed his petition.
Petitioner has been employed by the Los Angeles County
Probation Department since 1984. Petitioner was employed as a
supervisor at a juvenile detention camp at all times relevant to
this case. Petitioner received wages from Los Angeles County of
$41,139 in 1995, $42,372 in 1996, and $48,913 in 1997.
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