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least one other person. Petitioner husband's claimed training is
in the area of chemical engineering and electronics.
Prior to their marriage, petitioner husband was involved in
developing a golf club cleaning machine made by Ree-Born
Industries, Inc. Specifically, petitioner husband worked on
formulating the chemical solution used to clean golf clubs. He
also negotiated with Ree-Born Industries, Inc. for the rights to
market the machine to potential purchasers, such as country
clubs.
Petitioner husband experienced some financial difficulties
in his efforts to market the golf club cleaning machine. On July
1, 1989, he signed a promissory note, in the amount of $6,000,
payable to his current wife Martha Gregory. The promissory note
states that the entire debt was to be paid in a lump sum on
January 1, 1990, together with interest computed at a variable
rate. No payments were made on the moneys, if any, advanced to
petitioner husband, nor did petitioner wife ever request any such
payments.
Petitioners were married on March 15, 1990, and filed joint
Federal income tax returns for 1991 and 1992. On those returns,
petitioners claimed Schedule C deductions for alleged losses
resulting from their activity in "Information Brokering Products
& Services" operated under the name of MGO Information Services.
Petitioners also claimed a capital loss deduction in the amount
of $3,000 on their 1991 return. The deduction was claimed as a
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