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of $19,277. His mother received Social Security payments of at
least $4,342 in 1999.
On March 14, 1995, the State of Wisconsin filed articles of
organization of a "Limited Liability Company" (LLC), Daybreak IV
Fishing LLC (Daybreak). The organizers named in the articles are
petitioner and his father, Richard W. Corduan, Sr.
During 1999, Daybreak maintained a Web address at a cost of
$35. On January 16, 1999, petitioner wrote a letter to the State
of Wisconsin Department of Industry, Labor, and Human Relations,
UI Division declaring:
There has been no activity by Daybreak IV Fishing since
1995 and no employees or payments of wages has been
made since that time.
We have been through extreme financial problems
and any possibility of this venture ever being
resurrected are minute.
On January 17, 1999, petitioner wrote to the Department of
Revenue of the State of Wisconsin, stating: "There has been no
activity by Daybreak IV Fishing since 1995". He further
represented in the letter that the business "has been nonexistent
since 1995". The parties agree that Daybreak has never filed a
"Federal income tax return".
Petitioner reported his Daybreak activity on Schedule C as
producing gross receipts of zero, $5,037.70 in labor costs, car
and truck expenses of $2,079.89, legal and professional service
expenses of $13,580.37, rent or lease expenses for vehicles or
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