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petitioner and his family, with some of the bulldozing,
electrical wiring, and other similar work contracted out. All of
the houses were built for rental. Petitioner managed the rental
of all of the houses, three of which were owned by his children.
Petitioner's management activity included advertising, selecting
prospective tenants, and maintenance and improvement of the
houses.
About the time some of the first rental houses were being
built, petitioner also began attending night classes to obtain a
law degree. Sometime after receiving his law degree, petitioner
became a patent attorney.
In 1957, petitioner left his position with the U.S. Patent
Office and subsequently became employed by the U.S. Army Material
Command in the patent area.2 As a result of a "reduction in
force" petitioner's employment with that agency terminated in
1972. Petitioner thereafter did not pursue salaried employment.
From 1972 through 1991, the primary source of income for
petitioner and Mrs. Thomason was the rental of the houses in
Prince George's County, Maryland. During 1991, at least 90
percent of petitioner's income was derived from the rental of
these houses.
2
It is unclear from the record whether petitioner began his
duties at the U.S. Army Material Command as a patent attorney or
whether he began as a patent examiner and later became a patent
attorney.
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