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1985 and pursuant to section 6653(b)(1)(A) and (B) for 1986 and
1987.
FINDINGS OF FACT
Some of the facts have been deemed established for purposes
of this case in accordance with Rule 91(f).4 We incorporate
these facts into our findings by this reference. Petitioner
resided in Washington, D.C., on the date his petition was filed.
During the years at issue, petitioner conducted business as
a financial planner and consultant through four companies: Rice
& Associates; Ridgeway, Rice & Dill, Inc.; Integrated Financial
Concepts, Inc. (IFC); and Life Investors Group, Inc. Petitioner
sold insurance, promoted and sold various tax shelters, and
referred clients to his associate, Jim Dill (Mr. Dill), for tax
return preparation services.
When petitioner received clients’ payments for tax shelter
investments, he deposited them into his personal checking
accounts.5 Petitioner also deposited into his accounts the
proceeds from financial investment counseling fees, sales
4On Oct. 18, 2002, respondent filed a motion to show cause
why proposed facts in evidence should not be accepted as
established under Rule 91(f) and attached a proposed stipulation
of facts based on admissions. Petitioner failed to respond to
the Court’s order to show cause under Rule 91(f) issued on Oct.
18, 2002. As a result, on Nov. 15, 2002, the Court made the
order to show cause under Rule 91(f) absolute and deemed
established the facts and evidence set forth in respondent’s
proposed stipulation of facts.
5Over the course of the years at issue, petitioner used 12
personal checking accounts.
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