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Soon after he began flying with American Airlines, petitioner's
flight base was San Francisco, California, where he lived until
1974. In 1972, petitioner took advantage of the opportunity to
change his flight base to San Diego, California, and fly routes
primarily from San Diego to the east coast. After flying out of
San Diego for 2 years, petitioner moved his personal residence
there sometime during 1974.
In 1994, American Airlines closed its crew base at San
Diego, requiring pilots to bid for other flight bases in the
existing system. Consequently, from June 1994 to June 1995,
petitioner's flight base was Miami, Florida; from June 1995
through June 1996, petitioner's flight base was Chicago,
Illinois; and from June 1996 through May 1997, petitioner's
flight base was Seattle, Washington. During the last 3 years of
his employment with American Airlines, petitioner primarily
captained international flights to Europe, South America, and
Asia. Petitioner maintained his personal residence in the San
Diego area during all of these years.
Around 1990, petitioner began to realize that his retirement
was imminent, and he needed to become involved in new financial
endeavors that he could continue upon his retirement.
Petitioner's background in aviation led him to embark on an
activity commonly known as air racing. Air racing competitions
are held worldwide, in which participants fly private aircraft to
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