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one of the hotel rooms, which he used for the development of
solar electronic equipment. Petitioner bought four sailboats,
one in 1989, and three in 1990, to attract guests to the resort.
Petitioner intended to attract customers to the resort who were
interested in a healthy and naturalistic environment.
Bernadette Hendricks (Hendricks) has been petitioner’s
companion since before the years in issue, and, during the years
in issue, Hendricks, her children, and petitioner's children
regularly helped operate the resort. Petitioner hired Costa
Rican attorney Federico Alvarado (Alvarado) and his law firm,
Bufete, Robles, Lacle y Asociados, to provide legal services and
to assist in the maintenance of Playa de los Vivos when
petitioner was not present at the property.
Petitioner kept accurate books and records of the resort
activity's income and expenses. Petitioner printed brochures to
advertise the resort, and he offered the rooms for rent. From
1988 through 1995, most of the repair and maintenance expenses
incurred at the resort were for parts and supplies, and not
labor, because petitioner minimized costs by doing all of the
repair work at the resort himself.
By 1997, the land value of Playa de los Vivos had
appreciated substantially.
Petitioner’s home in Costa Rica is located on a separate
piece of property from Playa de los Vivos.
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Last modified: May 25, 2011