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friend in Sacramento", California. Petitioner and Mr. Bakos
planned to develop a ranch that belonged to Mr. Bakos' father
into a public golf course. The development of the golf course at
the ranch "did not pan out."
Petitioner's primary client for the year at issue was a
company named RO-TILE Roofing Co. (Ro-Tile). Of petitioner's
total gross receipts of $24,838 for the year reported on
Schedule C, Ro-Tile paid $23,186 to him for services that
included accounting, financial analysis, document drafting, court
appearances, and repairing a kiln. Petitioners also reported, on
Schedule A of their return, $3,780 in interest income from
Ro-Tile. Other clients paid another $1,652 to petitioner for his
services.
Petitioner maintained an office in his home in Yuba City for
his consulting business. Ro-Tile was located in Lodi,
California, south of Yuba City.
Petitioners' home had only one telephone line. Petitioner
used the telephone in his home as his business telephone. There
was also at least some limited personal use of the home
telephone.
Petitioners owned both a Ford pickup truck and a Lincoln
Continental automobile. Yoeng Yoep Dehr primarily used the
Lincoln as her personal vehicle. Petitioner used the truck to
drive from his home to and from Ro-Tile and other locations in
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