Julian O. Von Kalinowski and Penelope J. Von Kalinowski - Page 5

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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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