Robert C. Austin - Page 3

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          what his income was.  His father, a very successful businessman,            
          handled all of petitioner's investments and financial matters and           
          provided petitioner and his two sisters with a "protected and               
          cocooned life".                                                             
               During the years at issue, petitioner was an orchestra                 
          conductor.  Sometime in 1984, petitioner moved from Chattanooga,            
          Tennessee, to Cheyenne, Wyoming, to conduct the Cheyenne Symphony           
          Orchestra.  In approximately 1986, petitioner left Wyoming and              
          moved to Texas in order to conduct the East Texas Symphony                  
          Orchestra in Tyler, Texas.  Occasionally, petitioner made guest             
          appearances conducting other orchestras.  During 1988,                      
          petitioner's principal job was conducting the East Texas Symphony           
          Orchestra.  Petitioner's income from conducting in 1988 was                 
          approximately $43,000, the highest amount petitioner had ever               
          earned from conducting and what he considered a "handsome salary"           
          by the standards of his profession.  In 1989, petitioner was                
          fired from his job with the East Texas Symphony Orchestra, and              
          thereafter he moved from Lindale, Texas, to Dallas, Texas.                  
               A significant portion of petitioner's income derived from              
          investments his father had made in petitioner's name, including             
          securities and rental property.  Petitioner did not receive the             
          income from these investments directly.  The income was held in             
          an account at ROLICH, a corporation organized by petitioner's               
          father as a holding company to manage the assets that the father            
          had purchased and placed in the names of his three children.  The           

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