12
Year Gross Income COGS Expenses Gain/Loss
1977 $52,324 $29,673 $16,313 $6,338
1978 31,223 19,086 11,627 1510
1979 50,132 36,255 13,340 537
1980 19,864 7,304 13,399 (839)
1981 22,132 No record No record No record
1982 24,924 5,208 19,566 150
1983 38,281 17,013 26,095 1(4,827)
1984 19,912 9,955 19,531 (9,574)
1985 19,926 10,015 24,371 (14,460)
1986 15,731 8,618 25,265 (18,152)
1987 20,541 12,876 25,545 (17,880)
1988 10,375 6,190 21,015 (16,830)
1989 8,093 5,098 19,748 (16,753)
1990 3,867 2,502 19,253 (17,888)
1The parties stipulated to a $560 gain for 1978 and a $4,867
loss for 1983; however, the correct amounts appear to be a $510
gain for 1978 and a $4,827 loss for 1983.
The Schedule C cost of goods sold for 1990 in the amount of
$2,502 consisted of 4 large batteries. These batteries were
seized by the State of California.
OPINION
Respondent has conceded that petitioner has substantiated
the amounts in controversy. The primary issue to be decided is
whether petitioner's metal mining and refining activities for
1990 constituted an activity engaged in for profit within the
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