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made and received patient telephone calls at the Burl Avenue
residence and prepared for meetings with patients. He also
stored audio and video equipment at the Burl Avenue residence.
Petitioner’s main medical office was at 360 South Clovis
Avenue, Fresno, California (Fresno office). Petitioner also
maintained medical offices in Merced, California, and Burbank,
California.
Petitioner stored some of his film-making equipment at the
Burl Avenue residence because he believed it was more secure than
the studio where he had originally stored the equipment.
Petitioner’s film and music equipment was not inventory held for
sale to customers in the ordinary course of business but was
instead used by petitioner to make films and recordings.
In 1995, on the advice of Estate Preservation Services (EPS)
operated by Robert L. Henkell (Henkell), petitioner transferred
ownership of his medical practice, his movie and sound equipment,
his airplane and other vehicles, his personal residence, and
other assets to seven separate trusts. Attached as an appendix
to this opinion are a diagram and a schedule prepared by EPS
showing the ownership of petitioner’s trust entities and the flow
of funds among them. Petitioner’s revocable trust held complete
ownership of the “focus trust”, which in turn held complete
ownership of the remaining trusts. Petitioner retained direct or
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