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sole issue for decision is whether petitioner is entitled to
claim a Schedule C loss in the amount of $8,293 from his
“paralegal/boat repair business” for the taxable year 1992.
During these proceedings, petitioner filed a Motion to Dismiss
for Respondent’s Intentional Dirty Tricks, Bad Faith, and
Obstructive Behavior (motion). The Court took the motion under
submission at the conclusion of the trial.
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
included herein by this reference. Petitioner resided in Santa
Ana, California, at the time he filed his petition.
From 1959 to 1985, petitioner earned his living primarily as
a freelance boat worker/repairer. Petitioner would paint or
varnish a boat, do minor engine repairs (e.g., changing the
belts, sparkplugs, and pumps), transport a boat, or do just about
anything a client would need. Suffice it to say that petitioner
enjoyed working in the outdoors on boats. During this period,
petitioner purchased a substantial number of hand tools for use
in the boat repair activity. These included special fasteners
and bolts, screwdrivers, wrenches, power tools, drills, and
routers. In addition, petitioner purchased a bench saw, a band
saw, and a drill press.
Because of a series of unrelated injuries, petitioner was
forced to suspend his activities as a boat worker/repairer.
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