5
began outside employment. Petitioner’s wife was employed full
time as an assistant controller in a local television station
from 1983 to 1990. Subsequently, she became the controller for
that station. Before 1983, petitioner and his wife relied upon
income from petitioner’s mercury extraction activity as their
sole source of income. After 1983, Mrs. Massingill’s income
became the source of petitioners’ daily living expenses.
Furthermore, from 1984 to 1988, the reclamation of mercury
was not petitioner’s sole activity. Petitioner continued to
perform industrial instrumentation and control, as well as a
variety of research and development projects. Petitioner began
doing test extractions of metals from ores and minerals, as well
as the examination of properties, and performing amalgamation
assays. However, during those years, the recovery of mercury
from sources other than scrap batteries continued to be the
primary activity for petitioner.
Petitioner advertised mercury for sale in a periodical
called the "California Mining Journal". Sometime in 1982,
petitioner prepared a prospectus and attended a trade show for
the gold mining industry, involving both hobby and commercial
interests. The prospectus explained petitioner’s sale policies
to prospective clients. It was distributed by "Massingill
Metals" and includes petitioner’s phone number, address and
business hours. It states that any quantity of mercury may be
ordered, although clients are cautioned that some large orders
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011