- 12 - of an existing trade or business in the same field as that entered into by the taxpayer. Sec. 195(c)(1)(B). After petitioner sold Washington Chocolate, he decided he wanted to become an ancient artifacts dealer. Petitioner had developed an interest in ancient artifacts during childhood and had built a substantial personal collection. In the fall of 1989, petitioner traveled to Sedona, Arizona, and purchased his first artifact for his commercial inventory from Donald Corsette (Corsette). Throughout 1990, petitioner made frequent trips to Sedona and made several purchases from Corsette. In December 1990, petitioner traveled with Corsette to Geneva, Switzerland, where he purchased additional artifacts from Phoenix Ancient Art. Petitioner testified that when dealing in ancient artifacts, having a gallery bolsters a dealer's credibility. Therefore, during 1990 petitioner began to look for retail space in and around the Union Square area of San Francisco in which he could operate a gallery for his ancient artifacts. Petitioner located acceptable retail space in San Francisco, negotiated a lease, received drawings, and met with contractors who would construct leasehold improvements on the space. The plan for a San Francisco gallery was abandoned, however, because petitioner did not have sufficient inventory for the gallery space. Instead, petitioner decided he would operate his gallery from his personalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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