¶ During 1973 or early 1974, petitioner opened an art gallery on Madison Avenue in New York City where she specialized in original drawings of cartoons which she would sometimes purchase and sell outright or upon occasion sell under consignment. Nearby, she leased a four-room apartment where, on one wall of her living room, several of her pictures were displayed and where she occasionally entertained clients who might be interested in purchasing one or more of her pictures...
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