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Another aspect of petitioner's activity related to two citizens'
activist groups he organized, and, as to which, some of the
expenses were claimed as trade or business expenses on
petitioners' 1991 income tax return. In his testimony in
connection with a mailing list maintained for these activist
groups, petitioner testified:
[We] hit them again and again and again for the
American Energy Society and the American Energy
Association. And with those two organizations--
THE COURT: All right. Now those organizations,
were they corporations?
THE WITNESS: No, sir. They were not
incorporated.
THE COURT: What would they do, these two
organizations * * *
THE WITNESS: One thing they did was form under
that a citizens' action group. The purpose of the
citizens' action group was in cases like finding a
lawbreaker, which we did, and bringing a lawbreaker
into court, as we did. And when the lawbreaker was
found to be in defiance of court, then the court would
order that the lawbreaker would pay us a fee. It was
known as a private attorney general. So that was one
of the things that we engaged in.
THE COURT: So it was sort of like a whistle
blowing-like thing?
THE WITNESS: You've got the popular phrase for
it, sir.
Aside from the various rental properties petitioners owned and as
to which petitioners properly reported their income and expenses
on Schedule E of their 1991 return, the record supports a finding
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