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petitioner was required, inter alia, to work a certain amount of
time as a dive master assisting a dive instructor in teaching
individuals how to dive, which he did. While living in Hawaii,
petitioner spent $2,685.01 on various expenditures relating to
his diving activity. Sometime in December 1995, petitioner
received a dive-instructor rating from PADI.
In addition to the expenditures with respect to his diving
activity that petitioner made while living in Hawaii, petitioner
made the expenditures listed below when he was in Hawaii, Alaska,
Montana, Idaho, Washington, and/or perhaps other States and/or in
Canada:
Nature of Expenditure Amount of Expenditure
Long distance calls $684.38
Gasoline1 2,254.15
Clothes 603.77
Airfare 547.00
Parts 1,310.00
Union dues 1,105.50
Tools 1,787.04
Parts for recreational vehicle 119.95
Truck repair and maintenance 4,084.47
1This category does not include amounts spent for gasoline
by petitioner in Hawaii. That is because petitioner does not
claim as deductions any gasoline expenditures that he made while
he was living in Hawaii.
On December 21, 1993, in response to a letter written by
petitioner to the police department in Fairbanks, Alaska, in
which he alleged that certain of his tools with a value of
$40,000 were stolen from him sometime in 1991 (1991 purported
theft), police officer Coffey (Officer Coffey), a member of that
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