Frank W. George - Page 4




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          He is licensed as an osteopathic physician by the States of                  
          Arizona and Ohio.  He is also licensed as a homeopathic physician            
          by the State of Arizona.  During the years at issue, petitioner              
          operated a medical practice at his Scottsdale residence and at               
          other locations.                                                             
               3.   Petitioner's Post Office Box                                       
               During the years at issue, petitioner had a post office box             
          the address of which was 8711 E. Pinnacle Peak Road #121,                    
          Scottsdale, Arizona (the Pinnacle Peak address).  Petitioner had             
          a key and access to the post office box at all times in 1993 and             
          1994.  Petitioner used the Pinnacle Peak address on his 1993 tax             
          return and on checks from his checking account.                              
          B.   Stepping Stone Land Trust                                               
               On June 26, 1993, petitioner and Jimmy C. Chisum (Chisum)               
          formed the Stepping Stone Land Trust3 (Stepping Stone).  The                 
          trust agreement stated that petitioner was to transfer the                   
          Scottsdale residence to Stepping Stone.  He and Jones-George were            
          named as the beneficiaries of the trust.  However, Jones-George              
          did not participate in the trust and deeded her interest in the              
          trust to petitioner sometime before June 26, 1993.                           




               3 Our use of the words "trust", "trust agreement",                      
          "trustee", "transferor", and "form" in our findings of fact does             
          not necessarily indicate that we believe the transactions at                 
          issue have substance.                                                        





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