Sherman J. Miller and Alice K. Miller - Page 11

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            boat was never used by them in the years here in issue, but did                           
            not explain why they kept it.                                                             
                  Petitioner contends that all his social contacts in Hayward,                        
            which to an appreciable extent were while playing golf, were                              
            business meetings.  Petitioner offered a list of persons he                               
            claimed he met with in Hayward for business reasons.  Some of                             
            these persons who were called as witnesses by respondent at the                           
            trial testified that they had no recollection of meeting with                             
            petitioner to discuss insurance during the years here at issue.                           
            Mrs. Carolyn Butterbaugh had no recollection of discussing                                
            insurance with petitioner during the dates petitioner claimed to                          
            have met with her.  Mr. Richard Olsen stated that he never met                            
            with petitioner in the Hayward area.  He further testified that                           
            he never purchased insurance from petitioner.  Mr. John Rausch                            
            could not recall discussing insurance with petitioner.  Some of                           
            these persons did recall playing golf with petitioner or with                             
            petitioner and his wife at the Tagalong Club in the Hayward area.                         
            Some of the people petitioner claimed he had business meetings                            
            with in Hayward were from the St. Paul area.                                              
                  The discrepancy arising from petitioner's claims of business                        
            meetings with persons who denied they had business meetings with                          
            petitioner is explained by petitioner's definition of a business                          
            meeting.  Petitioner defined the prospecting aspect of his                                
            business as "introducing yourself, shaking hands, * * * making                            
            people like you and want to be with you".  Petitioner's business                          

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