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corporations. During the period at issue, petitioner worked as a
consultant to the Federal Reserve. As a consultant, petitioner
acted as an intermediary for the Federal Reserve and secured
financing for various projects, such as a high speed train and a
hospital. Petitioner received a percentage of the financing as a
fee for his efforts.
Between 1989 and 1994, petitioner attempted to secure $3.5
billion in financing for a Texas high speed train project to
connect Houston, Dallas, and Austin. Petitioner met with various
bank and trust representatives in Europe in an effort to finance
the train project.
Petitioners engaged in other side businesses between 1990
and 1993. In the 1940's, petitioner Barbara J. Burris (Mrs.
Burris) inherited from her father, B.H. Jester, a plot of land in
Austin, Texas. The land was developed under the names Jester
Development and Jester Estate Development (collectively, Jester).
Jester planned to build 1,100 houses on 1,000 acres of land.
Jester continued construction in 1990 and 1991, but construction
ceased at some point in the early 1990's due to the discovery
that the golden cheek warbler, an endangered species, inhabited
the property. Petitioners also owned interests in oil and gas
holdings during the years at issue.
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