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Abrams Co., owned by his brother-in-law. Petitioner also helped
his father, a carpenter, collect rent on houses his father owned
on the lower East Side of Manhattan. In the 1950's his father
sold those houses and purchased several apartment buildings in
Harlem. Together the buildings had a total of 28 apartment
units.
In 1960 petitioner's father passed away, and petitioner
inherited the apartment buildings. At that time petitioner's
brother-in-law offered to sell him an interest in Hy Abrams Co.,
but only if petitioner sold the apartment buildings so he could
devote more time to the business. Petitioner did so and invested
the proceeds in Hy Abrams Co. for a 30-percent interest. Hy
Abrams Co. became Hy Abrams Corp., and petitioner was named vice
president, although he continued to devote his attention
primarily to sales activities. In 1978 petitioner's brother-in-
law retired, and the corporation was liquidated. Petitioner was
not yet ready to retire, and with his daughter he started his own
floor covering business named Singer Carpet Distributors, Inc.
(Singer Carpet). Petitioner operated Singer Carpet out of a
warehouse in New Jersey for 4 years before retiring at the age of
68.
On their 1981 Federal income tax return, petitioners
reported gross income from wages, interest, dividends, and
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