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Subsequently, on May 31, 1996, petitioner received a check from
Brevard County for $15,920. As a result, petitioner did not file
a claim against the county.
In 1992, Mrs. Managan began taking courses at the University
of Central Florida (UCF). During 1995 and 1996, petitioner and
Mrs. Managan operated a Schedule C business, Monticello Research
Group (MRG), which conducted environmental audits of real
property. During this same period, Mrs. Managan attended UCF.
While attending UCF, Mrs. Managan did quality control work as an
independent contractor for a professor. In 1996, Mrs. Managan
received a bachelor’s degree in chemistry. In 1997, she began
working in a chemistry laboratory for BTR Labs.
During 1996, shortly after his motorcycle accident,
petitioner began constructing a boat, the Dinky Dau. Petitioner
intended to use the boat to fish for lobster off the coasts of
Honduras and Nicaragua. In 1996, petitioner paid $975 to his
attorney to obtain a lobster fishing license from Honduras.
OPINION
As a preliminary matter, petitioner contends that, pursuant
to section 7491(a), the burden of proof should be on respondent.
The parties agree that the examination began after July 22, 1998.
Respondent, however, contends that the burden of proof is on
petitioner because petitioner did not satisfy the requirements of
section 7491(a). In order for respondent to have the burden of
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