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Mr. Von Kalinowski gave petitioner an engagement ring and wedding
band in conjunction with their marriage, and shortly thereafter,
he bought her a fur coat costing approximately $4,000.
Petitioners took a number of trips from 1980 to 1983, yet
virtually all of them were related to Mr. Von Kalinowski’s
profession. The lone exception was a safari vacation to Kenya
which the couple took in either 1982 or 1983.
Petitioner’s Business Endeavors
Around the time of the couple’s marriage, Mr. Von Kalinowski
expressed his desire that petitioner not work outside of the home
in order that she could accompany him on his extensive business
travels and assist him with his social responsibilities. The
couple later discussed the possibility of petitioner's starting
her own business in order to accommodate petitioner’s desire to
work in a manner that would allow her to maintain autonomy over
her schedule.
In 1980, petitioner started Peter Dyer Interiors, a business
through which petitioner imported oil paintings for resale and
provided interior design services. Peter Dyer Interiors was
operational during 1981 and 1982, and generated net operating
losses of $4,322 and $9,740 during those years, respectively.
During 1983, petitioner took courses to become a travel
agent. In 1984, she and a faculty member of the school she
attended started a travel agency known as Windsor Travel.
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