Robert C. Austin - Page 6

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               In 1988, petitioner's father borrowed approximately $60,000            
          to $70,000 in petitioner's name in order to purchase securities             
          for petitioner.  Petitioner was not aware of these transactions             
          until respondent's audit examination of the years before the                
               Petitioner's grandfather had established a trust for the               
          benefit of his grandchildren.  Petitioner's share of the income             
          from this trust went to petitioner's father.  Petitioner was                
          unaware of this trust until respondent began the audit                      
               Petitioner's father had a power of attorney to act on                  
          petitioner's behalf.  The records regarding petitioner's various            
          sources of income, including Forms 1099 and W-2, were mailed to             
          petitioner's father in Tennessee.  Petitioner's tax returns for             
          all of his taxable years up through 1983 had been prepared by his           
          father.  Petitioner for some reason copied the returns over in              
          his own handwriting and then signed them.  Petitioner's tax                 
          returns for the taxable years 1981 through 1983 reported no tax             
               Around 1984 petitioner's mother became seriously ill.  She             
          spent about half of her time in the hospital.  Petitioner's                 
          father stayed with her while she was hospitalized during her                
          illness.  Apparently as a result of the mother's illness,                   
          petitioner's father ceased the preparation of petitioner's tax              

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