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On the upper level of the residence were 3 rooms in which
were located many of petitioners' business, financial, and
personal records, additional computers, and a bath. In one of
these rooms, Mrs. Kurzet reviewed, paid, and maintained files
relating to business and personal bills and activities. In the
other two rooms, petitioner maintained an office and a lab with
electronic circuit testing equipment related to ALS and his
consulting duties.
For 7 years, from 1984 to 1991, petitioner continued to be
available to act as a consultant to ALS, and petitioner received
a $10,000 per month consulting fee under the contract for the
sale of ALS.
Over the course of the 3 years in dispute, petitioner
actually performed for ALS consulting services 3 or 4 times a
year. Petitioner had no other clients as a consultant.
In connection with his consulting for ALS, petitioner had
access to the offices of ALS.
The primary real estate that petitioners owned and rented to
tenants consisted of a large industrial warehouse in southern
California. Petitioners also owned and rented to tenants two
condominiums in Park City, Utah. The evidence is not clear to
what extent petitioners used a real estate firm in Park City,
Utah, to manage the condominiums.
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