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B. JAM Bonding Co., Inc.
Around 1982, petitioners began to operate a bonding business
called JAM Bonding Co. (JAM Bonding). Several months after they
began to operate JAM Bonding, petitioners discussed their
business with Paul C. Oddo, Jr. (Oddo), a certified public
accountant. Oddo told petitioners the benefits of incorporating.
Petitioners decided to incorporate JAM Bonding. However, they
deferred incorporating it so they could deduct the losses on
their personal tax returns. James A. Bischoff (Bischoff), an
attorney, incorporated JAM Bonding.
Petitioners owned and operated JAM Bonding in 1990. JAM
Bonding's 1988 gross receipts were $502,900. Petitioners' income
from JAM Bonding was $94,000 in 1990.
C. Police Dog Training Business
1. Inception
Around 1989, petitioners decided to start a police dog
training business. Petitioner applied to the Bureau of Alcohol,
Tobacco and Firearms (BATF) and to the Drug Enforcement
Administration (DEA) for licenses to handle narcotics and
explosives needed to train police dogs.
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