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FINDINGS OF FACT
Petitioners resided at 62 Westwood Road, Shrewsbury,
Massachusetts, at the time they filed their petition. During the
years in issue, petitioners filed joint returns. Their 1988
return was not filed until January 31, 1990.
Petitioner wife, Evelyn Eresian (Evelyn), has been a title
examiner for approximately 54 years, and for several years,
including 1988 and 1989, she has owned one-third of Hobbs
Abstract Company. Petitioners reported $58,000 of wages from the
company for 1989. They also reported $83,000 of wages in 1988,
but the source of the 1988 wages is uncertain.
During the years in issue, Evelyn and her son, Ara Eresian,
Jr. (Ara), held as trustees four rental properties, most improved
with apartment houses. At least one of the properties, 16 Ripley
Street, Worcester, Massachusetts, was completely rented as of
January 28, 1988. Its five apartments rented for a total monthly
rental of $2,050. Nevertheless, none of the rental income from
any of these properties was reported on any Federal income tax
return for 1988 and 1989. The trust owning the properties failed
to file Federal income tax returns for the years in issue, and
petitioners' reported no rental income on their own returns.
Moreover, while both Evelyn and Ara, the two trustees, attended
trial, they failed to identify the beneficiaries of the trust.
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