- 4 -
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
intent:
THE COURT: * * * What is your hope for this
material?
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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