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“Non-Resident Alien” * * *.
On December 10, 1996, petitioners jointly executed a decla-
ration in which they stated the following:
I, Marvin L. Barmes/Barbara J. Barmes, hereby declare
that I do not have nor have I had any income from
Alcohol, Tobacco and Firearms. I also declare that I
do not have nor have I had a contract with the Depart-
ment of the Treasury to manufacture, sell, or distrib-
ute alcohol, tobacco, or firearms.
All gasoline used is and was purchased at a gasoline
service station.
I am not a federal employee.
I am not a corporation or partnership.
I am not effectively connected with the conduct of a
trade or business within the United States.
I was not involved in any revenue taxable activity.
I declare under penalty of perjury under the laws of
the united [sic] States of America that the foregoing
to the best of my knowledge and belief is true and
correct.
Respondent’s Communications with Petitioners with Respect
to Sandbar Wholesale Trust and Sandbar Real Estate Trust
On May 1, 1997, respondent’s revenue agent Rosetta Arnold
(revenue agent Arnold) issued two letters (revenue agent Arnold’s
two letters dated May 1, 1997), one of which was addressed to
“Sandbar Real Estate Trust, Attn: Marvin and Barbara Barmes,
Managing Agents” and the other of which was addressed to “Sandbar
Wholesale Trust, Attn: Marvin and Barbara Barmes, Managing
Agents”. Revenue agent Arnold’s two letters dated May 1, 1997,
were identical in content, except that one letter referenced
Sandbar Real Estate Trust and the other letter referenced Sandbar
Wholesale Trust. In those two letters, revenue agent Arnold
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