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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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