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business. On September 22, 1982, upon a guilty plea,
petitioner's father was convicted by the U.S. District Court for
the Western District of Kentucky on charges of conspiring to
unlawfully import marijuana into the United States and on other
drug charges; he received a 5-year prison sentence. On April 29,
1988, upon a guilty plea to charges of aiding others knowingly
and intentionally in unlawfully manufacturing a mixture or
substance containing marijuana, he was convicted and sentenced to
prison by the U.S. District Court for the District of Minnesota
for a term of 20 years, to be followed by 5 years of supervised
release.
F. Petitioner's Employment and Business Activities in 1989
and 1990
Throughout all of 1989 and 1990, petitioner was employed as
a paramedic by the Rescue Squad. Petitioner also began a dog
kennel business, known as Dry Creek Kennel, in 1990. Petitioner
constructed a garage and facilities for the kennel. He spent
$12,508 in cash for the construction. The kennel was not
successful. Petitioner did not engage in any other trade or
business activity in 1989 and 1990, nor did he win any money
gambling or in the lottery.
G. Petitioner's Tax Returns for 1989 and 1990
Petitioner is a calendar year, cash basis taxpayer. On his
1989 Form 1040EZ, Income Tax Return for Single Filers With No
Dependents, petitioner reported wages from the Rescue Squad in
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