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sales in 1958 by reason of his temporary lack of access
to a source of costume jewelry to sell is not
controlling. * * *
The present case involves petitioner’s claim for deductions
for expenses from two separate activities, boat repair and
paralegal work. Petitioner was engaged in the boat repair
business from 1959 through 1985 during which he accumulated a
substantial number of tools and supplies. In 1992, petitioner
incurred expenses for storage for these tools and supplies.
After 1985, petitioner did not perform boat repairs and did not
earn any income from that activity. As the years passed, it
became less and less likely that petitioner would ever return to
that activity or that his services would be desired by boat
owners or previous clients. There is no indication in the record
that petitioner maintained contact with his former clients in
this regard.
On the other hand, petitioner, after 1985, sought other
means of earning a living. He obtained his paralegal certificate
in 1989 and attempted to obtain employment. Beginning in
December 1989, he was successful through 1990, earning in excess
of $10,000 from that activity. All earnings from the paralegal
activity were as an employee. However, it became clear that
because of his physical infirmities, he would be unable to handle
the time restraints required of an employee, but he honestly and
sincerely believed that he could still function and earn money as
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