16 for any other aspect of the metal mining and refining activity in 1990. Petitioner also submitted a daily log of his activities which incorporates 1990. However, much of what is written down in that journal contains unexplained abbreviations. There are blank spaces for a large number of days each month for 1990. Moreover, petitioner’s compendium is not an adequate substitute for books or records of income and expenses. For example, unlike the records of sales of mercury, this does not list customers, the kind of work performed, and the amounts charged, if any. Thus, we cannot say that petitioner maintained adequate and accurate books of accounts. Petitioner’s marketing activities were, at best, minimal. He advertised in the "California Mining Journal". Petitioner distributed a prospectus on his sales policies to possible clients. He also attended trade shows where he could meet prospective customers. The records of sales of mercury show that most of petitioner’s clients came from within California. There were very few clients who were from out of State. Other than the above factors, petitioner presented no evidence that he actively sought business. Petitioner has not specifically shown any other marketing activities in 1990. In addition, petitioner had no business plan. At trial, petitioner testified that he did not expect to earn a profit immediately during 1986, before the dispute with DHS. He expected to do so in 1987 but did not do so. The record reflectsPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011