Tobias G. Ogu - Page 4

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          I.  Background                                                              
               Some of the facts have been stipulated, and they are so                
          found.  At the time that the petition was filed, petitioner                 
          resided in Houston, Texas.                                                  
               A.  Petitioner’s Occupation                                            
               Petitioner filed a Form 1040, U.S. Individual Income Tax               
          Return, for 1999.  At the bottom of page 2 of the Form 1040,                
          petitioner listed his occupation as “consultant” and his firm as            
          Americana Business Consultants.                                             
               Petitioner filed a Form 1040, U.S. Individual Income Tax               
          Return, for 2000.  At the bottom of page 2 of the Form 1040,                
          petitioner listed his occupation as “accountant” and his firm as            
          Creative Accountants.                                                       
               At trial, petitioner testified that he has a college degree            
          in business administration and that he regards himself as an                
          accountant both by education and profession.                                
               B.  Petitioner’s Schedules C                                           
               Petitioner attached a Schedule C, Profit or Loss From                  
          Business (Sole Proprietorship), to each of his returns for 1999             
          and 2000.  On each Schedule C, petitioner identified his business           
          name as Americana Business Consultants, his principal business or           




               3(...continued)                                                        
          employment tax deduction under sec. 164(f).                                 





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