James O. Jondahl - Page 6

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          Petitioner ran the day-to-day operations of Taxman.  Mr. Garaas             
          and Mr. and Mrs. Jondahl were not involved in Taxman’s day-to-day           
          operations.                                                                 
               Taxman’s business consisted of preparing Federal and State             
          tax returns, providing tax advice, and keeping financial books              
          and records.  Taxman employed several people at any one time                
          whose duties included preparation of tax returns, accounting                
          work, maintenance of accounts receivable and payable, making bank           
          deposits, signing checks, and receptionist tasks.  Taxman                   
          maintained bank accounts in its name, kept corporate records, and           
          filed corporate tax returns for the years in issue.                         
               In July 1985, petitioner was sued individually and as sole             
          proprietor of his tax preparation business.  Two of JFS’s clients           
          sued petitioner in connection with a tax shelter investment.  In            
          September 1986, a settlement was reached in which petitioner                
          initially agreed to pay each couple $6,000.  In connection with             
          the 1986 lawsuit against him, petitioner was deposed in July                
          1987.  During the deposition, petitioner stated that Taxman was             
          organized to take over the assets and liabilities of JFS.                   
          Petitioner testified in the deposition that he had transferred              
          office equipment worth approximately $10,000, accounts receivable           
          worth $3,000, and two bank loans totaling approximately $31,000             
          to Taxman.  Petitioner also stated that no written agreement                
          existed evidencing the takeover of JFS by Taxman.  After the 1987           






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