Harry E. Thomason and Estate of Hattie D. Thomason, Deceased, Mary T. Crist, Personal Representative - Page 3

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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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