Ronald I. and Lois B. Koenig - Page 12

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          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 personal           





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