James C. Estrada - Page 3

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          references are to the Tax Court Rules of Practice and Procedure.            
          Dollar amounts are rounded to the nearest dollar.                           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulations and the exhibits attached thereto are                      
          incorporated herein by this reference.  Petitioner resided in               
          Alta Loma, California, when he petitioned the Court.                        
               Petitioner is a nurse anesthetist.  Petitioner rendered                
          nurse anesthetist services on behalf of a partnership called                
          Newport Anesthesia Associates (NAA) for approximately 30 to 40              
          hours a week for 10 to 15 months during the years in issue.                 
          Since 1987, NAA has operated as a partnership, using petitioner's           
          address as its address.  The partnership agreement was entered              
          into between Renato Oania (Oania) and James C. Estrada CRNA Trust           
          (CRNA Trust) and was signed by Oania and petitioner; petitioner             
          signed the partnership agreement on behalf of the CRNA Trust.               
          Petitioner and Oania are the only people who have worked for and            
          administered anesthesia for NAA.                                            
               Dr. Peter J. Voloshin (Dr. Voloshin) has worked as a plastic           
          surgeon since 1986.  During 1991 and 1992, Dr. Voloshin operated            
          a business entitled Newport Institute of Surgery, P. James                  
          Voloshin, M.D., Inc. (NIS).  Dr. Voloshin's business maintained             
          operating room facilities and required the services of a nurse              
          anesthetist.                                                                






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