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reference.
When the petition was filed in the instant case, petitioner
resided in Norman, Oklahoma.
Background
Petitioner received a B.S. in engineering degree in 1964, an
M.B.A. degree in 1969, and a J.D. degree in 1974, all from the
University of Oklahoma. Petitioner has been a practicing
attorney since 1974. He is admitted to the bar of Oklahoma, and
is also admitted to practice before the U.S. Court of Appeals for
the Tenth Circuit and the U.S. Tax Court.
Petitioner married Pamela Hall (hereinafter sometimes
referred to as Pamela) on March 13, 1965. Petitioner and Pamela
remained married until their divorce on August 25, 1982.
Petitioner had two children of this marriage, born in 1966 and
1969. Petitioner had a third child, born in 1985. Petitioner
paid child support on behalf of all his children.
Beginning about 1981, petitioner suffered financial
setbacks. On February 11, 1987, petitioner filed for bankruptcy
in the U.S. Bankruptcy Court for the Western District of
Oklahoma, and was released from all dischargeable debts on June
18, 1987. During the years in issue, petitioner resided in small
living spaces and paid relatively little rent.
For the period 1982 through 1986, petitioner was a cash
basis taxpayer.
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