John Gallo - Page 2

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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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