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    6-

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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