Michael T. Chappell - Page 4




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               Petitioner’s father, Charles Chappell, has been a public               
          accountant in Montgomery for more than 30 years.                            
          B.   Petitioner’s Tax Preparation Business                                  
               Petitioner has operated an unincorporated income tax                   
          preparation business in Montgomery for 25 years.  He operated the           
          business from his home at 3314 Lower Wetumpka Road in Montgomery            
          in 1994 and 1995.                                                           
               Petitioner did not prepare or file any Forms W-2 (Wage and             
          Tax Statement) or Forms 1099-MISC (Miscellaneous Income) for his            
          tax preparation business in 1994 and 1995.                                  
          C.   Petitioner’s Houses                                                    
               1.   The Lower Wetumpka Road House                                     
               On October 2, 1992, petitioner bought a house at 3314 Lower            
          Wetumpka Road (the Lower Wetumpka Road house) in Montgomery for             
          $30,000.  Petitioner financed $29,000 of the purchase price                 
          through the sellers.  Petitioner made the monthly payments on the           
          mortgage (usually $279.42, including taxes and insurance) from              
          his Colonial Bank account.  He paid $3,258.33 in 1994 and                   
          $2,235.36 in 1995.                                                          
               The Lower Wetumpka Road house has 918 square feet and                  
          contains four rooms and a kitchen and bathroom.  Petitioner used            
          the large room in the front of the house as a waiting room during           
          tax filing season.  It was also used by the Freedom Quilting Bee,           
          a 150-year old quilting cooperative, on whose behalf petitioner             






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