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Unless otherwise stated, section references are to the
Internal Revenue Code. Rule references are to the Tax Court
Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners are married and resided in Sarasota, Florida, in
1999, 2000, and 2001, and when they filed the petition in this
case.
A. Petitioner
1. Petitioner’s Employment With TruGreen Lawn Care
Petitioner has a bachelor’s degree in psychology and 45
credit hours toward a master’s degree in biology. Petitioner was
director of human resources and marketing for TruGreen Lawn Care
(TruGreen) in 1998 and early in 1999 until TruGreen discharged
him. Petitioner sued TruGreen for wrongful discharge and
received a settlement in 2000 of $100,000 plus payment of $16,500
in legal expenses petitioner incurred in that case. The law firm
of Nelson Hesse represented petitioner in that lawsuit.
2. Petitioner’s Consulting Activity and Volunteer Work
After being discharged by TruGreen, petitioner offered
consulting services to clients relating to marketing, media, and
public relations in 1999-2001. Petitioner’s consulting activity
was a sole proprietorship.
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