Joseph R. and Diana K. Trudel - Page 4




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          housing, local automobile repair services, and restaurant                   
          reviews.  After approximately 9 months of operation, the                    
          newsletter had 43 subscribers who each paid $9 for an annual                
          subscription.  The newsletter never generated any significant               
          revenue, and petitioner discontinued publication after only a few           
          years.  Petitioner was employed as a computer programmer                    
          throughout the time he published the newsletter.  After                     
          terminating publication of his newsletter, petitioner began                 
          contributing occasional film and theater reviews to local                   
          newspapers.  The newspapers paid him $50 per article.  Petitioner           
          also claims that he made use of his writing ability in various              
          employments over the years.                                                 
               During the summer of 1997, petitioner and his wife took an             
          8-week road trip from California to the east coast and back.                
          Petitioner claims that they took the trip so that he could write            
          a series of articles about various Civil War sites.  His alleged            
          target audience was people who were interested in both traveling            
          and the Civil War.  During the trip petitioner visited Civil War            
          sites and conducted several interviews.  Petitioner wrote seven             
          3- to 5-page articles that he submitted to national magazines               
          including the National Geographic, AAA Magazine, Via Magazine,              
          and Travel & Leisure.                                                       
               Petitioner failed to arrange publication of any of his                 
          articles.  Petitioner had no gross receipts from his writing                
          activity during 1997 and has never received any compensation for            




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