2
After concessions,2 the issues for decision are: (1)
Whether petitioner has substantiated the payment of expenses
related to his jewelry design activity for 1990 and 1991; and (2)
if so, whether petitioner was engaged in this activity for profit
during those years.
Some of the facts have been stipulated and are so found.
The stipulations and the exhibits attached thereto are
incorporated herein by this reference. Petitioner resided in
Portland, Oregon, at the time his petition was filed.
Petitioner had training in mineral recognition and completed
courses in lapidary and jewelry mounting. In 1982, petitioner
began designing, making, and selling jewelry (referred to herein
as petitioner's jewelry design activity). Petitioner also
performed jewelry services such as mountings and repairs.
Petitioner carried on this activity under the name Adams Design
Jewelry which he registered with the town of Beaverton, Oregon,
in April 1984. Petitioner conducted this activity in his home
until the summer of 1988, at which time he rented a shop located
at 625 Southwest Washington Street in downtown Portland, Oregon.
Petitioner leased the property on a month-to-month basis.
Near the end of 1989, petitioner decided that he should
abandon the shop location because it was not successful.
2 Petitioner has conceded adjustments to his 1990 taxable
income in the amount of $1,615. Petitioner has paid the amount
of the deficiency attributable thereto.
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