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With such a substantial amount of free time, petitioner
obtained a Connecticut home improvement contractor's license and
started a construction business in 1987. The business provided
him with financial security in the event his piloting career was
not successful. He specialized in carpentry work on home
improvements such as remodelings, additions, and decks.
Petitioner believed that there was higher income potential
in constructing new homes than remodeling existing ones. In
March 1989, he acquired an unimproved lot in East Lyme,
Connecticut (East Lyme property) for the purpose of building a
single family home. The East Lyme property was petitioner's
first new home construction project. Petitioner wanted to
establish a reputation for himself as a new home builder and
anticipated that the East Lyme property would serve as his
"calling card". He believed people would see the quality of his
work and hire him to build other new homes.
Petitioner obtained a second mortgage on his personal
residence to finance the 10-percent downpayment on the unimproved
lot. The balance of the funds for the construction project was
obtained in a commercial construction loan from Mechanic's
Savings Bank in Hartford, Connecticut. The bank took a security
interest in the East Lyme property as collateral for the loan.
There was a significant amount of risk for petitioner in
building a home without a predetermined buyer, but he believed
that he would make a modest profit on the East Lyme property and
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