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From 1979 to 1988, Raymond owned a one-third interest in a
corporation that owned four video stores. In 1988, the stores
closed because they could not compete with larger video stores
such as Blockbuster.
Except for his sports memorabilia activity, Raymond was not
otherwise employed from 1988 until 1997. In 1991, Barbara
attended college full time, paying for her schooling with student
loans. She began working as a teacher in May 1992.
In order to supplement their income to cover living expenses
incurred from 1990 through 1992, petitioners refinanced their
house, maximized their credit card balances, and used money they
had saved for their children's educations. Although some of
petitioners' personal expenses were paid out of the National City
Bank account, Raymond paid most of petitioners' living expenses
with cash.
In 1990, Raymond made a $10,000 profit from an autograph
session with Jim Brown.
Raymond bought and sold sports memorabilia, sports
memorabilia supplies, and other collectibles during 1991 and
1992. Raymond did not maintain any books or records (including
inventory records) regarding the sales and purchases of these
items.
In 1991, Raymond traded baseball cards for an automobile
worth $2,000. In 1992, Raymond paid $1,500 for a motor home and
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