Curtis G. and Edna L. Lockett - Page 3

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          afflicted with sickle cell anemia.  Petitioner developed what he            
          referred to as a "compound" that he administered to his daughter            
          and that, to petitioner's satisfaction, placed her sickle cell              
          anemia in remission.  Petitioner was convinced that his compound            
          was effective because, for a time period in which he was unable             
          to administer the compound to his daughter, her condition                   
          worsened, and she lost her left eye.  When the compound was again           
          administered to her, she became well.                                       
               Petitioner is not a doctor of medicine, although he holds a            
          college degree in biology, chemistry, and physics.  For the years           
          prior to the years in question, petitioner did not consider his             
          home laboratory as a trade or business for tax purposes.  Also,             
          the record does not indicate that petitioner ever contacted or              
          made known to doctors and/or pharmaceutical companies his                   
          development of the compound, which he was satisfied relieved his            
          daughter of her sickle cell anemia.  Petitioner did not                     
          administer this compound to anyone other than his daughter, nor             
          did he ever sell or market the compound.  He was of the belief              
          that his compound would be effective in suppressing AIDS and                
          other human immune system problems.                                         
               Sometime in 1991, or a short time prior thereto, petitioner            
          decided to proceed commercially with his compound.  He                      
          discontinued his contracting business and spent considerable                
          amounts of money in improving his laboratory.  He adopted a trade           

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