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and designed and managed rubbish removal and recycling programs.
Omega was also involved in farming activity on approximately
1,400 acres of land leased from the Christian Boys Ranch, Inc.
(CBR).
From 1990 through 1995, petitioners reported passthrough
income from Omega on Schedules E, Supplemental Income and Loss,
attached to their individual income tax returns as follows:
Year Net Income
1990 $52,303
1991 57,867
1992 51,437
1993 217,787
1994 483,949
1995 660,375
For the same period Robert O’Connor (petitioner) reported
wages as follows:
Year Amount
1990 $40,900
1991 52,869
1992 47,394
1993 50,390
1994 53,618
1995 46,894
Petitioners organized CBR under the nonprofit laws of the
State of California on June 24, 1982. CBR is a section 501(c)(3)
corporation for tax reporting purposes. Petitioner has served on
CBR’s board of directors and as its president since its
incorporation in 1982. Karen O’Connor has also served on CBR’s
board of directors and as CBR’s vice president and secretary-
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