William W. Halle IV, and Janice C. Halle - Page 6

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          from November 1, 1989, to October 31, 1990.  The lease agreement            
          called for 12 payments in the amount of $525 per month.                     
               In December 1990, petitioner moved his family, personal                
          residence, and locksmith business to his current location in                
          Cheyenne, Wyoming.  He continued to operate his locksmith                   
          business in Wyoming and used a portion of his Wyoming residence             
          for his locksmith shop.                                                     
               In December 1990, petitioners signed an agreement with North           
          American Van Lines to transport their belongings from New Jersey            
          to Wyoming.  Actual delivery was made by North Park                         
          Transportation Co. on January 10, 1991.  Although petitioners               
          contracted to sell their New Jersey personal residence in                   
          December 1990, the sale did not occur until February 1991.                  
               In 1990, petitioner used two vehicles in his locksmith                 
          business, a Chevrolet Cavalier and a Chevrolet van.  Petitioner             
          owned the Cavalier, having acquired it in 1986 at a cost of                 
          $13,500.  Until 1990, the Cavalier was used 100 percent for                 
          personal purposes.  On June 1, 1990, petitioner converted the               
          Cavalier to 56 percent business use.  On December 20, 1990,                 
          petitioner traded in the Cavalier as a downpayment on a 4 year              
          lease for a Chevrolet van.  The amount credited to petitioner for           
          the Cavalier trade-in was $2,000.  The van was used 100 percent             
          for petitioner's locksmith business.  His lease payments for the            
          van were $301 per month.                                                    






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