Quentin Paul DeFore - Page 5

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          college.  As a pipe fitter, petitioner performed maintenance and            
          construction work for a variety of heavy industrial plants, paper           
          mills, steel mills, and refineries, such as Exxon and Shell.                
               Ms. DeFore was engaged in a variety of fields during her               
          marriage with petitioner.  She attended high school through the             
          11th grade and then worked as a race horse jockey for 14 years.             
          Upon retirement, Ms. DeFore worked on construction jobs with                
          petitioner and held a few positions with various retailers before           
          commencing work for a real estate developer midway through 2001.            
          The deficiency in the couple’s 2001 joint Federal income tax                
          return arose from Ms. DeFore’s performance of services for that             
          real estate developer, Darrell Hall.                                        
               It appears that Ms. DeFore’s work for Mr. Hall consisted               
          largely of showing undeveloped lots to prospective buyers.3  If a           
          prospective buyer decided to purchase a lot, the buyer would then           
          return to the office with Ms. DeFore and select a house floor               
          plan.  Because Ms. DeFore dealt only with undeveloped lots and              
          not finished homes, she did not need a real estate license.                 
               Ms. DeFore continued working for Mr. Hall through the                  
          beginning of 2002, after which she worked for Paul Turner, who              
          owned three western stores.  In March 2002, Ms. DeFore left for             



               3    As Ms. DeFore was not present at trial, petitioner                
          provided the only testimony concerning the nature of Ms. DeFore’s           
          work for Mr. Hall.                                                          





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