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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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