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used for many purposes including computer chips, tanks, and
bulletproof vests. In 1993, petitioner began teaching Indian
tribes in Mexico how to identify and mine jade. Petitioners
believe that jade mining can be a source of revenue for these
Indian tribes. Petitioners also claim to have consulted with
major computer companies, the United States Government, and high-
level officials of the Governments of Brazil and China regarding
the uses of jade.
Petitioner contends that he founded Glacial Jadeite as a
sole proprietorship in 1991. However, we are unable to discern
whether Glacial Jadeite is conducted as a sole proprietorship, a
partnership, or as a joint venture. In the record, Glacial
Jadeite is described as "a group of associated persons".
Moreover, petitioners did not file a Schedule C with their 1993,
1994, and 1995 Federal income tax returns indicating that they
operated a sole proprietorship. Petitioners have also failed to
explain their financial interest in Glacial Jadeite. In fact,
petitioners have failed to provide any details regarding Glacial
Jadeite's ownership. Rather, petitioners contend that they were
consultants to Glacial Jadeite in 1996.
Petitioners claim that Glacial Jadeite was involved in many
profitable projects during 1996.1 Petitioners have failed to
1 As an example, petitioners allege that Glacial Jadeite is
involved in the construction of hotels and that the first floor
(continued...)
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