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of section 183, and (2) if so, whether petitioners have
substantiated the nature and amount of various deductions they
claimed on the Schedule C attached to their 1996 Federal income
tax return.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
San Diego, California, when the petition in this case was filed.
References to petitioner in the singular are to petitioner
Raymond B. Marvin.
During 1996, petitioner was employed as an airport shuttle
driver and cashier by Laurel Travel. In 1996, petitioner
received wages from Laurel Travel in the amount of $11,155.90.
During 1996, petitioner Joan M. Marvin was employed by Marriott
International. In 1996, petitioner Joan M. Marvin received wages
from Marriott International in the amount of $17,513.49.
Petitioner became interested in jade and geology in 1972.
Petitioner does not have a college degree in geology. Rather,
petitioner claims to have learned about jade primarily from his
stepfather.
During 1996, petitioners were also engaged in an activity
named Glacial Jadeite (the jade activity). Petitioners assert
that the jade activity involved consulting, researching, and
developing uses for jade. Petitioners claim that jade can be
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