John Charles Treadaway, Sr. - Page 3




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          a 2,000-square-foot house located on that property.  The North              
          83d Avenue property also contained a guest house which adjoined             
          petitioner’s residence and a swimming pool.                                 
               At least five automotive vehicles were used and/or kept at             
          the North 83d Avenue property, including two pickup trucks and              
          three automobiles.  Neither petitioner nor Ms. Treadaway was able           
          to drive any of those vehicles during the years at issue.                   
               As of the trial in this case, petitioner had been operating            
          a tax consulting business (tax consulting business) for approxi-            
          mately 30 years.  As part of that activity, petitioner repre-               
          sented taxpayers before the Internal Revenue Service.  During the           
          years at issue, petitioner operated the tax consulting business             
          from a room located in petitioner’s residence.                              
               Ms. Treadaway, who began riding horses when she was about              
          six years old, started providing horse-training and other horse-            
          related services around 1929.  (We shall refer to those horse-              
          related services as horse-training activities.)  At least during            
          the years at issue, the horse-training activities were conducted            
          on the North 83d Avenue property.  Ms. Treadaway continued her              
          riding and the horse-training activities until she was no longer            
          able to do so because of her deteriorating medical condition,               
          which included Alzheimer’s disease.  As of July 1994, Ms.                   
          Treadaway’s Alzheimer’s disease was in an advanced stage.  As a             
          result of Ms. Treadaway’s medical condition, Ms. Treadaway was              






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