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of the tax liens were filed with the Broward County Circuit Court
in Fort Lauderdale, Florida (Broward County).
Federal Tax Returns
Petitioner’s business affairs and his tax returns were
handled by David Simon (Simon), a certified public accountant, in
Florida. Simon was petitioner’s business manager beginning in
the early 1990's.
Simon prepared Forms 4868, Application for Automatic
Extension of Time to File a U.S. Individual Income Tax Return,
for 1995 and 1996 showing petitioner’s address in Hallandale. On
September 19, 1997, petitioner filed his Form 1040, U.S.
Individual Income Tax Return, for 1995. Petitioner attached two
Forms W-2, Wage and Tax Statement, to the Form 1040. The
Form 1040 and the two Forms W-2 showed petitioner’s address in
Hallandale. On November 3, 1997, petitioner filed his Form 1040
for 1996, with attached Forms W-2. The Form 1040 and the
Forms W-2 all listed the same Hallandale address.
Petitioner did not file a California Resident Income Tax
Return for any year prior to 1999.
Pension Plan
At the time of trial, petitioner was a production manager in
California. He had been employed in the film and television
business for 30 years. For all years relevant to this
proceeding, petitioner participated in a basic and a supplemental
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