Frank George - Page 4




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          money paid to the trust for petitioner’s services is taxable                
          income to petitioner.                                                       
               During 1998, the IRS commenced an examination of                       
          petitioner’s returns for the years in issue.  The revenue agent             
          reviewed petitioner’s returns, Arivada’s returns, HOMC’s returns,           
          correspondence from petitioner to various other employees of the            
          IRS, documents at the Arizona Corporation Commission and the                
          recorder’s office, records for bank accounts, and checks signed             
          by petitioner.  The revenue agent issued summonses for bank                 
          account records and analyzed them, concluding that the deposits             
          shown were similar to the amounts reported on the HOMC returns.             
          Petitioner did not provide any documents during the examination             
          and did not meet with the revenue agent who had audited his                 
          account until December 6, 2001, less than 2 months before trial             
          of this case.                                                               
               Petitioner filed a chapter 13 bankruptcy petition with the             
          U.S. Bankruptcy Court for the District of Arizona on October 19,            
          1998.  On October 21, 1998, the bankruptcy court lifted the stay            
          so that litigation in petitioner’s case for 1993 and 1994 could             
          proceed.  The notice of deficiency in this case was sent to                 
          petitioner on July 3, 2000.  Petitioner’s chapter 13 bankruptcy             
          case was dismissed on December 26, 2000.                                    
               Arivada filed a bankruptcy petition on or about October 22,            
          1998.  Arivada’s bankruptcy case was dismissed on November 23,              






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