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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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