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in the amount of $10,000 from his credit union to purchase all of
this equipment.4
Petitioner kept his computer in a garage that he had
converted into an office. Petitioner spent an average of 2 to 3
hours each evening in his garage office. Generally, petitioner
spent more time in the garage office during the weekends.
Petitioner spent much of this time setting up the computer,
installing the software, debugging the system, and learning how
to use the computer and software. In addition, petitioner spent
time learning to use MLS. Although the computer allegedly was
primarily used for petitioner's real estate activities, he has
recently installed some computer games for his children.
Petitioner kept no records of the amount of time he devoted
to his real estate activity in 1991. During his first 2 years as
a real estate salesperson, petitioner learned the basics of how
to be a real estate salesperson. By attending seminars and
training courses or teaching himself, petitioner learned how to
make cold calls, do appraisals, download data, and use MLS.
During 1991, petitioner had no income from his real estate
activity and did not have any clients. However, respondent did
4 Petitioner's opportunity to supplement the record was
extended to include a copy of the loan agreement. See supra note
3. It is unclear whether the software for the MLS service was
purchased prior to petitioner's obtaining his real estate license
and becoming associated with REP.
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