Thomas C. Sandoval, Jr. and Bobbie J. Sandoval - Page 4

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          A.   Petitioners                                                            
               Petitioners lived in San Antonio, Texas, when they filed               
          their petition.                                                             
               During the years in issue, petitioner was sole proprietor of           
          Allied Electric and Air Conditioning Co. (Allied Electric)                  
          located on Hoefgen Avenue (Hoefgen Avenue property) in San                  
          Antonio.  There was a billboard and a commercial sign (the two              
          outdoor advertising signs) on the Hoefgen Avenue property.                  
               Petitioner bought the following vehicles for Allied                    
          Electric because he thought he needed them for contracts on which           
          he had bid, but which he did not win:                                       
          Vehicle                    Date acquired                                    
          1973 Ford Digger              October 1982                                  
          1972 Ford Bucket truck        February 1983                                 
          1977 GMC Bobtail              April 1983                                    
          1977 GMC Bobtail              April 1983                                    
          1985 Ram Charger              October 1984                                  
          He maintained them, but he did not register or insure them until            
          he began to use them for his business in 1985.                              
          B.   The Hoefgen Avenue Property                                            
               1.   Addition of Storage Space and Office                              
               Between January 1, 1982, and December 31, 1984, petitioner             
          added warehouse storage space and an office addition to the                 
          second story of the Hoefgen Avenue property.  Richard Zamora                
          (Zamora) drafted plans for the storage space addition in November           

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