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stock, to the extent that any stock had been issued and was
outstanding. Suffola generated no income during 2000, and the
corporation did not file a Federal income tax return for that
year. The record is unclear with respect to the exact services
that petitioner might have provided to Suffola during the year in
issue, but whatever they were, he did not receive a salary or any
other form of compensation as a result.
Petitioner’s employment with Cooper Union continued
throughout 2000, as did his formal education there. He took
several courses in pursuit of a doctorate degree that year.
According to petitioner, his education was geared towards
advancing the corporate goals of Suffola, although those goals
are less than clearly stated in the record. Nevertheless, in
pursuit of his doctorate degree, petitioner incurred tuition
expenses, as well as expenses for books and supplies. During
2000, petitioner also purchased a laptop computer, a scanner, and
a digital camera.
During 2000, petitioner contributed financially to the care
and maintenance of his mother, who was ill and cared for by his
sister.
Petitioner’s 2000 Federal income tax return was timely
filed. That return includes a Schedule A on which, as relevant
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