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A. Petitioner
Petitioner resided in Salt Lake City, Utah, when the
petition was filed. He was married to Brenda J. Clark (Mrs.
Clark) during the years in issue.
Petitioner studied finance at Idaho State University. He
has a degree in accounting from Brigham Young University. Over
the years, petitioner has worked as a distribution clerk, truck
driver, stockbroker, and restaurant owner and as sole proprietor
of a business known as Totally Awesome Internet (TAI).
Petitioner and his family formerly lived in Idaho.
Petitioner moved to Salt Lake City in June 1997 to work for Boise
Cascade Office Products, but he did not work for that company
after November 25, 1997. His family moved to Salt Lake City in
1998. Petitioner worked intermittently for Dell Super Computers
during the years in issue.
B. Petitioner’s Tax Returns
Petitioner and Mrs. Clark filed a joint Form 1040, U.S.
Individual Income Tax Return, for 1998, which respondent received
on November 19, 2000. On that return, they reported $56,991 of
gross income, $3,820 of taxable income, $2,022 tax due, and
$6,409 tax withheld, and they claimed a $4,387 refund. They
deducted $35,304 for moving expenses and $9,767 for itemized
deductions. Petitioner kept few if any records. About $20,000
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