Edward D. Lang and Sharon A. Lang - Page 4




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               On January 5, 1988, Trisch registered DRD as an assumed name             
          in Kerr County.  Trisch listed only himself on the assumed name               
          certificate for DRD.                                                          
               Petitioner moved from Houston to San Antonio in 1988.  He                
          received rental payments and deposited them in a bank account for             
          DRD in San Antonio in 1989.  Petitioner closed this account in                
          late 1989 or early 1990.  After 1989, Trisch handled all DRD                  
          activities, and petitioner was not involved in DRD.  Trisch told              
          petitioner (on a date not stated in the record) that DRD was                  
          being dissolved and had been inactive since about 1990.                       
          C.   Trisch’s Engineering Services                                            
               During the years in issue, DRD received about $4.8 million               
          for engineering services that Trisch provided to various                      
          companies (engineering income).2  Petitioner never agreed that                
          DRD would provide engineering services.  Petitioner did not know              
          about or perform any of these engineering services, or know about             
          or control any of the engineering income.                                     
               Pace paid DRD for engineering services that Trisch performed             
          for Pace’s business from 1989 to 1993.  Pace understood that DRD              
          was Trisch’s sole proprietorship during those years.  Bankers who             



               2  Respondent determined that DRD received a total of                    
          $4,818,314 in engineering income:  $713,775 in 1989; $1,018,500               
          in 1990; $1,134,377 in 1991; $782,000 in 1992; and $1,169,662 in              
          1993.                                                                         






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