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acquired any San Diego office space other than 20 The Point in
1986, 1987, and 1988. Instead, at all times, Terry continued to
maintain the Alessandro office in Riverside. As with Mary
Street, petitioners suggested that they tried to sell the
Alessandro office, but it was difficult to sell. However, they
presented no documentary evidence to corroborate this statement.
As of January 1, 1987, Terry became an employee of Academy,
and with the Corporation's liquidation in August 1988 Terry was
no longer self-employed. In regard to his employment with
Academy, Terry's job expanded outside California, requiring
extensive travel. During a substantial portion of the period at
issue, and in particular from August 31 to September 23, Terry
was traveling regularly outside California on business. When
Terry traveled, Joyce stayed at Mary Street or remained at 20 The
Point.
Furnishings: We know that, at a minimum, petitioners lived
at Mary Street for 15 years (1973-88). Yet there is no record of
moving any belongings from Riverside to Coronado. In response to
this observation, petitioners point to the fact that the
Corporation purchased 20 The Point fully furnished, and upon
liquidation petitioners received the furnishings. Therefore,
according to petitioners, there was no need to hire a moving van
to move belongings from Mary Street to 20 The Point. However,
this explanation is questionable considering the fact that
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