John Gallo - Page 3

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          Hoping and expecting that some day he would be able to return to            
          the business, petitioner stored his tools in a commercial                   
          facility.  In 1992, the cost of the storage was $1,980.  Near the           
          end of 1993 or the beginning of 1994, petitioner disposed of the            
               Before 1989, petitioner enrolled in Coastline Community                
          College (Coastline) and studied in its real estate program.                 
          Petitioner earned an AA degree and a certificate in real estate.            
          He then obtained a real estate salesman’s license.  In addition,            
          he studied the escrow field and obtained an escrow certificate.             
          Moreover, in early 1989, petitioner obtained from Coastline a               
          certificate of achievement in legal assisting, which licensed               
          petitioner as a paralegal.  Prior to that time, petitioner was              
          involved in a serious car accident that required substantial                
          medical care and physical therapy.                                          
               Petitioner’s physical condition was such that he was not               
          able to accept work as a paralegal until December 1989.  In 1989            
          and 1990, petitioner earned $220 and $8,430, respectively,                  
          working as a paralegal “temp” for an agency that placed                     
          paralegals in either temporary or permanent positions.  Also in             
          1990, petitioner earned $2,696 as an employee of a paralegal                
          services company that did on-site and off-site paralegal project            
          work for various law firms and other entities.  The parties have            
          stipulated that “in 1989 and 1990, the petitioner regularly                 

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