Wilbur Kenneth Griesmer - Page 4

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               Petitioner also collected various pyrites, which he regarded            
          as precious metals.5  According to petitioner, "I purchase maybe             
          tons and tons of this stuff * * * from Europe, Greenland, South              
          America".  Petitioner has not made any attempt to sell his                   
          pyrites, but rather regards his collection as his legacy to                  
          certain individuals.6                                                        
               Petitioner did not maintain any records for his meteorite               
          and pyrite collection activity.                                              
               Petitioner filed Federal income tax returns (Forms 1040) for            
          1995 and 1996, disclosing his occupation as "self-employed                   
          physicist".  Petitioner attached to each of his returns a                    
          Schedule C (Profit or Loss From Business) in the name of "The                

          5  "Pyrites", according to Webster's Unabridged Third New                    
          International Dictionary, at 1853 (1993), are "any of various                
          metallic-looking sulfides of which pyrite is the commonest",                 
          whereas "pyrite" is "a common mineral that consists of iron                  
          disulfide  FeS2 * * * and is burned in making sulfur dioxide and             
          sulfuric acid".                                                              
          6  The following colloquy at trial reveals petitioner's                      
                    THE COURT:  * * * What is your hope for this                       
                    PETITIONER:  Well, I got maybe grandchildren or                    
               possible grandchildren that live next door to me.                       
               They're possible grandchildren; I'm not sure.  I want                   
               them to be able to enjoy life as well as I enjoy life.                  

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