Ronald L. Heidrick - Page 4




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          construction company.  His employer was not in the gold mining              
          business.  Petitioner began searching for gold using a pan,                 
          shovel, and pick in 1982.  In 1989, using his knowledge of                  
          dredging gained from his employment, he began mining for gold in            
          rivers and streams in the foothills of mountains.  Petitioner               
          maintained his regular job, expecting that the mining activity              
          would supplement his income.  He mined sometimes at night but               
          mostly on weekends because of the demands of his regular job.  He           
          was able to perform additional mining during layoff periods.                
               Petitioner read mining literature and attended a few                   
          meetings with others interested in gold mining but otherwise had            
          no formal training in the activity.  He admired the work of                 
          author Dave McCracken, who has made a profit in gold dredging.              
          According to petitioner, the McCracken operation enlists others             
          to dredge for the gold that McCracken ultimately keeps.  Other              
          than a window-washing business in 1978 or 1979, petitioner was              
          not engaged in other trade or business activities.                          
               Petitioner’s gold mining activity involved time, effort,               
          money, and risk.  After identifying a site for prospecting,                 
          petitioner would haul heavy dredging equipment to the site.  He             
          was a certified scuba diver.  To search for gold, he would dive             
          to depths of 25 to 30 feet and operate the dredging equipment for           
          up to 8 to 10 hours.  Mud, gravel, and other material from the              
          river were brought up and screened through what was referred to             





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