Raymond B. and Joan M. Marvin - Page 2




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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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