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FINDINGS OF FACT2
Petitioner resided in Loveland, Colorado, at the time his
petition was filed in this case. For taxable years 1992, 1993,
and 1994, petitioner owned and operated a construction business,
which did business under the name of K&L Exteriors Trim (K&L
Exteriors). The business of K&L Exteriors was residential
construction, in particular house framing and siding work.
Petitioner graduated from high school in 1986 and then began
employment as a construction laborer. After 1 year, petitioner
began full-time attendance at Aims Community College. Following
his first year, petitioner transferred to the University of
Northern Colorado, which he attended for 1 year.
After his second year of college, petitioner moved to
Minnesota to work for his grandfather, who owned and operated an
electric motor repair business. He worked for his grandfather
for approximately 1 year. He subsequently moved back to Colorado
and re-enrolled in the University of Northern Colorado. He
attended for two quarters and then transferred for an additional
semester to Colorado State University for an additional semester,
where he studied a specialized curriculum on construction.
Petitioner did not earn a college degree.
2 Some facts have been stipulated by the parties and are
herein incorporated by this reference.
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