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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
Court.
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
examination.
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
liability.
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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