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FINDINGS OF FACT1
At the time the petition was filed, petitioners resided in
Woodland Hills, California. Petitioners are cash basis
taxpayers. Michael A. Schmitt (petitioner) is a law professor at
Southwestern University School of Law in Los Angeles, California,
and is licensed to practice law in the State of California. From
1984 through the time of trial, petitioner operated a sole
proprietorship under the name Legal Education Conference Center
(LECC).
LECC offered a full-service bar review course and
supplemental workshops to law school graduates who were preparing
to take the California bar examination. The full service bar
review course covered substantive areas of law tested on the
California bar examination, including both the National
multistate law and California State law components of the bar
examination. LECC also offered three supplemental workshops that
each focused on a specific area of testing on the California bar
examination: Essay writing, performance skills, and the
multistate law component. The bar review course and workshops
were offered twice a year coinciding with the testing times for
the California bar examination, which is given in February and
July of each year. LECC also offered a preliminary bar review
1 The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
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