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Petitioner vacated the shop premises in March 1990. Petitioner
removed fixtures from the shop including six jewelry cases.
Petitioner retained one of the cases for use in his activity at
home and placed the other five in storage in his home.
Petitioner's jewelry design activity generated gross receipts of
$637 in 1990. Petitioner's customers were past customers or
friends of friends.
Petitioner was employed full time as a technical writer by
Tektronics during part of 1990 and by Mitron Corporation for a
portion of 1990 and for all of 1991.
In 1990, petitioner decided to engage in a second activity,
and he began to create correspondence courses. In the first
year, petitioner offered two basic jewelry making classes and two
basic technical writing classes. Petitioner's correspondence
school activity generated gross receipts of $320.
In 1991, petitioner placed two or three advertisements in
the Oregonian newspaper, but otherwise he did not actively
solicit sales of jewelry in 1991. During the year, petitioner
had gross receipts for this activity of $528 from three jewelry
mountings. In that same year, petitioner's correspondence school
activity generated gross receipts of $480.
Petitioner's record of the expenses that he paid in
connection with his jewelry design activity is in the form of a
bookkeeping notebook. The book contains an expense log by month.
For each month, entries are posted on one side of the page
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