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business. During those years, Charles Harp Construction, which
petitioner operated from an office located in Hillsboro, Oregon
(Hillsboro), acted as a general contractor. As such, Charles
Harp Construction located and purchased lots as sites for the
construction of houses, worked with lenders to obtain financing
for its purchase and construction activities, hired and
supervised subcontractors with respect to those construction
activities, and arranged for the sales of the houses it con-
structed. During the years at issue, petitioner generally
financed his sole proprietorship activities by obtaining con-
struction loans from Washington Federal Savings Bank (Washington
Federal) at its branch in Portland, Oregon (Portland branch),
where its construction loan department was located.
During 1989, petitioner's license as a general contractor
expired, at which time Charles Harp Construction ceased undertak-
ing any new construction projects. At some unknown time during
1990, Charles Harp Construction completely terminated its opera-
tions except for limited activities that generally consisted of
selling houses constructed prior to that year.
During 1989 and 1990, petitioner maintained the books and
records, including the general ledger, of his sole proprietorship
and issued checks in payment of expenditures that he incurred in
connection with the operations of that business.
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