Raymond F. Kling and Barbara K. Kling - Page 4




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          and 100 Cleveland Indians programs.2                                        
               Raymond goes to flea markets five or six times a week.  He             
          attends baseball card shows once or twice a month.  Raymond does            
          not have a booth to sell cards at the shows, but he trades, buys,           
          and sells cards at the shows.  Over the years, Raymond created a            
          cash hoard primarily from periodic sales of his memorabilia.                
               For about 20 years, Raymond has stored most of the items he            
          has collected in part of an old building (the warehouse).                   
          Although Raymond displayed some of his sports cards and                     
          collectibles in the front part of the warehouse, most of the                
          items were in disorganized piles.  The warehouse is known as Ohio           
          Hobby Dealers Supply.  Raymond pays $500 per month rent for the             
          warehouse.  In addition to the warehouse, the building also                 
          houses a gym, a travel agency, a mission, and a print shop.                 
               Raymond also stores some of his memorabilia in an old church           
          building that he rents from St. Vladimir's.  He began renting               
          with a 3-year option to purchase from St. Vladimir's in 1991 or             
          1992.  He paid from $200 to $500 per month for rent and $5,000              
          for the option to purchase.  At the end of the 3-year option                
          period, Raymond did not purchase the building and forfeited the             
          $5,000.                                                                     
               Raymond did not deduct on his income tax returns the rent              
          paid for any site where the items he has collected were stored.             

               2Raymond used to clean out Cleveland Stadium.  After every             
          game he would collect all of the unused scorecards and programs.            




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