Ronald F. and Linda C. Bernard - Page 2

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          decision is whether petitioners are entitled to costs of goods              
          sold and deductions for a Schedule C model train retail business            
          in 1994.                                                                    
                                  FINDINGS OF FACT                                    
               Most of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Petitioners resided in              
          Sacramento, California, at the time the original petition was               
          filed in this case.                                                         
               In 1994, Ronald F. Bernard (petitioner) quit his job with              
          the State of California, withdrew all his State retirement                  
          money,1 and used this money, along with his savings, to open a              
          retail store specializing in model trains (the store).                      
          Petitioner planned to call the store “California Model Trains”.             
               Petitioner located a promising site for his store in a mall            
          (the mall) which was under construction in Folsom, California.              
          The contractor building the mall told petitioner that                       
          construction would be completed in time for petitioner to occupy            
          the premises in November 1994.  Petitioner expected to have a               
          very high percentage of his annual sales occur in November and              
          December during the holiday season.                                         



               1  Petitioners reported this withdrawal--$41,323.09--as                
          income on their 1994 joint Federal income tax return.                       




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