Harm De Boer - Page 9

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               Petitioner is a skilled mechanic and engineer.  His long               
          hours of work on the drill rig, in the face of his inability to             
          find work for it, are attributable both to the profit that he               
          expected to earn from its operation and disposition and the                 
          enjoyment he derived from working on the equipment, upgrading it,           
          and keeping it in a state of readiness.                                     
               Petitioner reported taxable income of $35,354 and a tax                
          liability of $7,774 on his Federal income tax return for 1985.              
          However, foreign tax credits arising from petitioner's foreign              
          source income from his work overseas reduced that liability to              
          zero.  Petitioner reported no taxable income and a tax liability            
          of zero on each of his Federal income tax returns for the period            
          1986 through 1991.                                                          



          8(...continued)                                                             
               The largest decline in the spot price of crude oil occurred            
          in 1986, and the price never recovered during the relevant period           
          to 1984-85 levels.                                                          
               Selected domestic prices per barrel follow:                            
                    Year                                          Price               
                    1984 average..................................$25.88              
                    1985 average.................................. 24.09              
                    1986 average.................................. 12.51              
                    1987 average.................................. 15.40              
                    1988 average.................................. 12.58              
                    1989 average.................................. 15.86              
                    1990 average.................................. 20.03              
                    1991 average.................................. 16.54              
          Energy Information Administration/Historical Monthly Energy                 
          Review 1973-1992, at 249.                                                   




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