Marcelo E. Ferrada and Gloria D. Ferrada - Page 4

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          a different department.  His position also changed from quality             
          control to manufacturing engineer.  The terms of Mr. Ferrada's              
          employment remained open-ended.                                             
               At the end of 1997, Mr. Ferrada moved his wife and son to              
          Del Rio, Texas.  Mrs. Ferrada and their son lived rent-free in a            
          mobile trailer owned by Mrs. Ferrada's parents.  Mr. Ferrada                
          continued to work in Lake Charles.  In December 1998,                       
          anticipating long-term employment, Mr. Ferrada moved his family             
          to Lake Charles.  He continued to work on the project through               
          1999.                                                                       
          2.   Concession Stand                                                       
               In May 1998 petitioners purchased a concession stand for               
          approximately $4,000.  During 1998, petitioners had gross                   
          receipts of $710 from the concession stand which they did not               
          report on their tax return.  They also incurred $2,315 of                   
          expenses.                                                                   
               Petitioners' Individual Income Tax Return for 1998                     
               On April 14, 2000, petitioners jointly filed with the                  
          Internal Revenue Service a Form 1040, U.S. Individual Income Tax            
          Return, for tax year 1998.  Attached to the return was a Schedule           
          A, Itemized Deductions, and a Schedule C.  The Schedule C                   
          reported zero business income, expenses of $48,612, and a net               
          loss of $48,612.                                                            








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