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Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioners’
legal residence was Memphis, Tennessee.
Petitioner has a bachelor of science degree in accounting
from East Tennessee State University and, since the mid-1960's,
has worked in the field of accounting and tax return preparation.
In 1964 or 1965, petitioner was employed by the Internal Revenue
Service (IRS) as a revenue agent in Memphis, Tennessee. In the
early 1970's, he left the IRS to work as a comptroller for Stax
Records (Stax) in Memphis. After about 18 months with Stax, he
left that employment and started a business known as Memphis
Talent Consultants to provide business, financial, and tax advice
to recording artists. During the 1970's and 1980's, petitioner
traveled to various cities in the United States, including
Nashville, Tennessee, Los Angeles, California, Washington, D.C.,
and Detroit, Michigan, in an attempt to attract clients for his
consulting business. From the early to mid-1980's, petitioner
rented an apartment in Nashville where he set up an office in the
living and dining room areas. He used the apartment bedrooms as
living quarters when he stayed overnight in Nashville. That
office was closed during 1986 or 1987.
During the late 1980's and early 1990's, petitioner had
various clients in Memphis and Los Angeles for whom he performed
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