Tolbert S. Wilkinson and Suzanne T. Wilkinson - Page 3

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          authenticity.  Petitioner seeks to introduce the exhibits to show           
          that the records were kept, and that these were the records, but            
          not necessarily that these records were correct or accurate.  The           
          admission of these documents for that limited purpose will not              
          prejudice respondent, and accordingly the objection is overruled.           
          Petitioners resided in San Antonio, Texas, at the time the                  
          petition was filed, and filed joint income tax returns for the              
          years in issue.  References to petitioner are to Tolbert S.                 
          Wilkinson.                                                                  
               Petitioner was a plastic surgeon employed by the Institute             
          for Aesthetic Plastic Surgery (the Institute), a corporation                
          wholly owned by petitioner in the years in issue.  Petitioner               
          wife is also employed by the Institute.  Petitioner received his            
          undergraduate degree from Wake Forest University, graduated from            
          Duke University Medical School in 1962, and has practiced in the            
          field of surgery.  Petitioner has no formal education in                    
          agriculture, horses, cattle, or farming/ranching-related                    
          activities.                                                                 
               Petitioner has been involved with horses in different                  
          capacities since the mid-1970's.  Petitioner became involved in             
          polo in the early 1980's.  The Retama Polo Center near San                  
          Antonio attracted petitioner because it hosted numerous large               
          social events which garnered a great deal of publicity.                     
          Petitioner concluded early in his career that because his                   
          services were elective, there was a limited clientele who could             




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