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corporation engaged in the development and sale of computers and
software.
ECC was ultimately unsuccessful, and, in 1985, petitioner
abandoned the corporation and moved to Florida. Petitioner
obtained a Florida real estate broker license, and went to work
for IBEX Business Brokers, Inc. (IBEX). According to his own
testimony, petitioner did not sell a single property during his
tenure with IBEX, and, at some point thereafter, he went to work
for the School Board of Pinellas County as an engineer and
consultant. During 1988 and 1989, the years at issue, petitioner
earned an annual income from his position with the School Board
in the respective amounts of $20,989.55 and $28,116.43.
Petitioner testified that although he worked full time for
the School Board, approximately 40 hours each week, he had time
during the day for other activities. He further testified that
he used this time, in addition to evenings and weekends, to
independently pursue his brokerage activities, spending 15 to 20
hours per week trying to list and sell properties. To date, he
has yet to sell any such property.
Petitioner maintained no formal ledgers or records of his
brokerage activities, nor did he maintain separate bank accounts.
He did not have a separate business telephone number and did not
advertise his services on a regular basis.
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