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in excess of 59 days working on the Harwichport property,
excluding travel time between the Harwichport property and
petitioner's residence in Wallingford, Connecticut.
In the Boston Globe on October 28, 1990, petitioner
advertised the Harwichport property for sale, "completely
furnished", for $154,500. In November 1990, petitioner placed
similar advertisements in the Cape Codder, and the Providence
Journal. There were no advertisements in 1990 offering the
property for rent.
Petitioner's employment as a police officer included the use
of an unmarked police car. The only restriction on petitioner's
use of the police car was that he could not take that vehicle
outside the State of Connecticut. Petitioner owned a Lincoln
Continental (Lincoln) which he left parked at his father's house
located in Warren, Connecticut. When petitioner needed to travel
to the Harwichport property, he would park his police car at his
father's house. Petitioner would then drive the Lincoln to the
Harwichport property. On the Form 4562 attached to petitioner's
1990 Form 1040, petitioner indicated a business use percentage of
90 percent for the Lincoln. Petitioner did not respond to the
questions "Do you have evidence to support the business use
claimed?" and "If 'Yes,' is the evidence written?" that appear on
lines 22a and 22b, respectively, of Form 4562.
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