B. Albert and Betty M. Holowinski - Page 3

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          Mrs. Holowinski read a book entitled "How to Make Money in                  
          Antiques".  Mr. Holowinski spoke with an accountant, Alan Myers             
          (Mr. Myers), about bookkeeping and tax matters.                             
               In April 1992, petitioners began buying antique glassware.             
          Petitioners continued to purchase antique glassware throughout              
          the years in issue, focusing primarily on glass produced by a               
          company named Westmoreland Glass (Westmoreland) that conducted              
          business from 1875 to 1985.  Petitioners traveled to antique                
          conventions and to antique shops throughout the central United              
          States in search of Westmoreland glassware.  Petitioners' travels           
          took them to various States including Kansas, Ohio, Tennessee,              
          Iowa, Nebraska, Oklahoma, Texas, Arkansas, and Illinois.                    
          Petitioners envisioned purchasing glassware for approximately 40            
          to 50 percent of its potential resale value.  During the taxable            
          years 1992, 1993, and 1994 petitioners spent $7,173, $7,471, and            
          $4,144, respectively, for glassware.  Petitioners stored the                
          glassware in their home, placing the inexpensive pieces in their            
          basement and the more valuable pieces upstairs where the                    
          temperature remained constant.  Some glassware was displayed on             
          the walls of various living areas of petitioners' home and in               
          china cabinets.                                                             
               Mrs. Holowinski spent approximately 40 hours per week on the           
          antique glassware sales activity, which petitioners called Albe's           
          Antiques, and Mr. Holowinski spent 20 to 30 hours per week.                 

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