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petitioner started a consulting business. He also began a home
improvement business, operating under the name “J&M Enterprises”.
Petitioner’s mother owned an apartment in Shrewsbury, New Jersey.
Over the years, petitioner repaired, cleaned, managed, and found
tenants for that apartment.6 Petitioner spent approximately 1
week each year maintaining and managing the apartment.
In 1982, petitioner filed a business name certificate with
the State of New Jersey, certifying that he was conducting a
business under the name “The Logistics Technology Group.” The
nature of the business was described as defense electronics
consulting services, real estate dealer activities, and home
improvement services. Petitioner opened a bank account titled
“Logistics Technology Group” (the LTG account).
In 1986, petitioner and Mrs. Wood purchased a house in
Hilton Head, South Carolina (the South Carolina house), and, in
1987, they purchased a 1-week timeshare unit in Gulfstream,
Florida (the Gulfstream timeshare), for $7,900.
In 1988, petitioner and Mrs. Wood purchased land in Boca
Raton, Florida, and, in 1989, they hired a builder to construct a
home on that property (the Florida house). To help finance the
construction of the Florida house, petitioner and Mrs. Wood sold
the South Carolina house in 1989.
6Petitioner began these activities in 1972 and continued
them through 1996.
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