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managed the farm and maintained the books and records relating to
the farm.
In 1981, the Baileys transferred their 50-percent equity
interest in the farm to petitioner and to petitioner's parents,
and thereafter petitioner and his parents together owned 100
percent of the farm.
On June 15, 1982, petitioner transferred to his parents his
interest in the farm.
In October 1982 and subsequent years, petitioner invested at
least $17,000 in several oil and gas wells in Texas.
In 1986, petitioner terminated the accounting partnership
with Patricia Brink and established an accounting partnership
with Terry Hankins. In 1987, petitioner terminated the
accounting partnership with Terry Hankins and established an
accounting practice as a sole proprietor.
On April 29, 1988, petitioner filed in the U.S. Bankruptcy
Court for the Southern District of Texas (Bankruptcy Court) a
petition, case No. 88-00732, for relief under chapter 7 of the
Bankruptcy Code. On September 1, 1988, the Bankruptcy Court
issued an order discharging petitioner's then-existing
dischargeable debts.
On July 2, 1990, a storage unit that petitioner rented was
broken into, and petitioner's property was stolen therefrom. On
a report of the theft filed with the rental storage company,
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