Terry Duane Beall and Joyce Engel Beall - Page 18

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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           
               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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