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
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
nature of the business was described as defense electronics
consulting services, real estate dealer activities, and home
“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
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.