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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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