- 11 - 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 asPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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