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incorporated herein by this reference. At the time of filing the
petition, petitioners resided in San Jose, California.
Petitioners have been married to each other since 1969. At the
time of filing the petition, petitioners were in the process of
dissolving their marriage; they have lived in separate abodes
since 1997.
Petitioner Ray Sowards (Mr. Sowards) worked for Pacific Gas
and Electric (PG&E) until he became disabled in the mid-1980s. He
received disability income from PG&E during the years at issue.
Mr. Sowards graduated from Lincoln Law School in 1985. He was a
licensed attorney in the State of California at the time the
returns at issue were filed. Additionally, during the
aforementioned period, Mr. Sowards was admitted to practice
before this Court.
After graduating from law school, Mr. Sowards opened a law
practice. His practice concentrated on what he described as
asset protection. In or about the end of 1993 or 1994, Mr.
Sowards became acquainted with Robert Strong (Mr. Strong). Mr.
Strong operated a business entity known as System Two Limited
(STL). STL was in the tax and financial services business, and
it prepared tax returns. As part of this business, STL promoted
business trusts. STL’s promotion activities included seminars.
Mr. Sowards participated in these promotion activities. During
the years at issue, Mr. Sowards worked at an office located at
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