James O. Jondahl - Page 2

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          1991, 1992, and 1993 of $19,078.50, $2,162.25, $7,412.25, and               
          $26,907, respectively.  After concessions by the parties, the               
          issues for decision are:                                                    
               (1)  Whether assessment of petitioner’s 1990, 1991, 1992,              
          and 1993 taxes is barred by the period of limitations in section            
          6501(a).  Because we find that petitioner filed false and                   
          fraudulent returns with the intent to evade tax for 1990, 1991,             
          1992, and 1993, we hold that assessment is not barred;                      
               (2)  whether Taxman, Inc. (Taxman), and West Fargo                     
          Investment Corp. (WFIC) should be disregarded because they are              
          mere alter egos of petitioner.  We hold that they should not;               
               (3)  whether petitioner earned real estate commissions of              
          $56,196, $18,552, $1,566, and $139,080 in 1990, 1991, 1992, and             
          1993, respectively.  We hold that petitioner earned a real estate           
          commission of $1,566 in 1992 and that petitioner did not earn               
          real estate commissions in 1990, 1991, or 1993;                             
               (4)  whether petitioner realized capital gain of $25,000               
          from the sale of Jondahl Insurance in 1990 and commissions from             
          the sale of crop hail insurance in 1990 and 1991 of $12,882 and             
          $3,142, respectively.  We hold that petitioner received capital             
          gain of $14,962 and insurance commissions of $10,038 in 1990, and           
          that petitioner did not earn insurance commissions in 1991;                 









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