Gunasundran R. Pillay and Kalaivani Govender - Page 3

                                        - 2 -                                         
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               Respondent determined deficiencies of $4,586 and $3,929 in             
          petitioners’ 2000 and 2001 Federal income taxes, respectively.              
          After concessions by petitioners,1 the issue for decision is                
          whether petitioners are entitled to expense deductions in the               
          taxable years 2000 and 2001 related to a sole proprietorship.               
                                     Background                                       
               These two cases were consolidated for purposes of trial,               
          briefing, and opinion.  Some of the facts have been stipulated,             
          and they are so found.  The stipulation of facts and the                    
          supplemental stipulation of facts with attached exhibits, as well           
          as an additional exhibit admitted during trial, are incorporated            
          herein by this reference.  Petitioners Gunasundran R. Pillay (Mr.           
          Pillay) and Kalaivani Govender are married and resided in Citrus            
          Heights, California, when the petition in each docket was filed.            
          Unless otherwise indicated, all references to petitioner are to             
          Mr. Pillay.                                                                 






               1 Petitioners concede that a $1,175 State income tax refund            
          they received in 2001 is taxable.  Petitioners also concede                 
          certain expense deductions claimed on their Schedule C, Profit or           
          Loss From Business, which are discussed infra.  The remaining               
          adjustments in the notices of deficiency are computational;                 
          therefore, we do not address them.                                          




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