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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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