Steven Bruce Huntley - Page 4

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               During the taxable year 2000, petitioner received wages,               
          unemployment compensation, and a distribution from an individual            
          retirement account (IRA) totaling $34,025.  Petitioner does not             
          contest that he received these amounts or that they are                     
          includable in his gross income.  However, at trial, petitioner              
          raised the issue of his entitlement to two loss deductions.                 
               On October 8, 2000, petitioner filed articles of                       
          incorporation with the secretary of the Commonwealth of                     
          Pennsylvania for Huntley Quality Assurance, Inc. (HQA).  In                 
          September 2000, HQA entered into a general Contractor agreement             
          with Howard Systems International, Inc. (Howard Systems, Inc.),             
          for petitioner to provide software support services at Wyeth-               
          Aryst Pharmaceutical from September 25, 2000, through March 25,             
          2001.  Petitioner worked at Wyeth-Aryst Pharmaceutical from                 
          September 24 through October 8, 2001, for a total of 59.5 hours             
          at $80 an hour.                                                             
               Petitioner did not timely file his 2000 Federal income tax             
          return.  Respondent prepared a substitute return calculating                
          petitioner’s tax liability for 2000.  Respondent issued a notice            
          of deficiency based upon amounts reported as paid to him by                 
          payors, using the filing status of married filing separately.  In           
          his calculation, respondent allowed the standard deduction of               
          $3,675 and a personal exemption allowance of $2,800.                        







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