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Background
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. At the time the petition
was filed, petitioner resided in Federal Way, Washington.
In January 1994, petitioner purchased a nonoperating beauty
salon. Petitioner had no previous experience in owning or
operating a beauty salon and had no training in cutting hair.
Petitioner worked full time in the human resource department of a
company located in Bellevue, Washington. The salon was
approximately 1,100 square feet in area and was equipped with
hairdressing stations, or chairs, and other fixtures, including
equipment for shampooing and drying hair. At the time of
purchase, the salon had no employees and was not open for
business. In February 1994, petitioner hired the first
beautician and thereafter opened for business. Petitioner
advertised the salon’s services in newspapers and on the radio.
Maxi’s provided services for clients who made appointments with a
particular beautician or were walk-in customers. By the end of
the first quarter of 1994; i.e., March 31, 1994, petitioner had
hired three to four beauticians. Due to the high turnover in
this type of business, petitioner had approximately 20
beauticians working in Maxi’s during the years at issue, although
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