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He is licensed as an osteopathic physician by the States of
Arizona and Ohio. He is also licensed as a homeopathic physician
by the State of Arizona. During the years at issue, petitioner
operated a medical practice at his Scottsdale residence and at
other locations.
3. Petitioner's Post Office Box
During the years at issue, petitioner had a post office box
the address of which was 8711 E. Pinnacle Peak Road #121,
Scottsdale, Arizona (the Pinnacle Peak address). Petitioner had
a key and access to the post office box at all times in 1993 and
1994. Petitioner used the Pinnacle Peak address on his 1993 tax
return and on checks from his checking account.
B. Stepping Stone Land Trust
On June 26, 1993, petitioner and Jimmy C. Chisum (Chisum)
formed the Stepping Stone Land Trust3 (Stepping Stone). The
trust agreement stated that petitioner was to transfer the
Scottsdale residence to Stepping Stone. He and Jones-George were
named as the beneficiaries of the trust. However, Jones-George
did not participate in the trust and deeded her interest in the
trust to petitioner sometime before June 26, 1993.
3 Our use of the words "trust", "trust agreement",
"trustee", "transferor", and "form" in our findings of fact does
not necessarily indicate that we believe the transactions at
issue have substance.
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