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their home. As further described below, he also engaged in
various additional activities to produce income.2 Mrs. Viar was
a bookkeeper. Petitioners filed joint income tax returns,
prepared by a return preparer, for 1999 and 2000.
Mr. Viar was a licensed real estate agent. He began selling
homes in 1995. Prior to 1995, he was a contractor installing
water and waste treatment plants throughout Virginia.
During the years at issue, Mr. Viar was an employee of CMH
Homes, Inc., on whose behalf he sold mobile homes. In this
activity during the years in question, Mr. Viar occasionally took
clients to lunch. He did not keep detailed records of his meals
and entertainment expenses. He used his own vehicle to show real
estate throughout five counties. He did not keep a mileage log.
In a separate self-employed activity, Mr. Viar provided the
necessary amenities for the mobile homes sold by CMH Homes,
including grading the land site, digging water wells, installing
the septic systems, constructing the brick underpinnings, and, in
some cases, installing a basement. The work required travel to
county seats and to the location of each home. Mr. Viar used his
own vehicle for these services, for which he was not reimbursed
2 Respondent did not argue that Mr. Viar’s additional
activities were activities not engaged in for profit under sec.
183(a).
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