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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and exhibits submitted therewith are
incorporated herein by this reference. Petitioner resided in
Lockport, Illinois, when he petitioned the Court.
Petitioner has been an accountant and tax return preparer
for over 28 years, and he has a bachelor’s degree in accounting
from Lewis College in Lockport, Illinois. Petitioner worked as a
revenue agent for the Internal Revenue Service (the Service) for
5 years in the 1970's. While he was at the Service, his duties
included auditing Federal income tax returns of individuals and
corporations. Petitioner has prepared thousands of Federal
income tax returns in his career, and he is knowledgeable about
the Federal income tax laws. Petitioner has also set up hundreds
of corporations for various individuals, and he serves as
registered agent for at least 163 of these corporations.
Petitioner is married to Charlene House (Charlene), and they
have two sons, Craig House (Craig) and Tim House (Tim). Craig
was a construction worker in 1994, and he built at least two
homes during 1992 through 1994. Tim was a college student at the
University of Central Florida in 1994. During all relevant
times, petitioner, Charlene, and Craig lived at 210 Muehl,
Lockport, Illinois (Muehl residence). The Muehl residence was
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