Petitioner Emil Horowitz conducted a business as a wholesale dealer of secondhand jewelry during 1972 and 1973. The inventory of the business consisted primarily of diamonds, precious stones and other expensive jewelry. Horowitz also was involved in the operation of standardbred racing stables during the years in question. He was the owner of a 50% interest in Poet Acres Farms Partnership until its dissolution in the fiscal year ending August 31, 1972. Horowitz and his wife...
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