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proceed with collection of petitioners’ 1997 and 1998 income tax
liabilities.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, stipulation of settled issues, and
attached exhibits are incorporated herein by this reference. At
the time they filed the petition, petitioners resided in
Bellevue, Washington.
At the time of trial, Phillip Aaron (petitioner) and Gladies
Aaron had been married for 35 years. Mrs. Aaron works for the
State of Washington as a social worker. Petitioner is an
attorney in private practice and also owns interests in various
closely held corporations.
In the latter part of 1996, petitioner’s health declined. In
the beginning of 1997, petitioner was diagnosed with colon cancer
and underwent surgery immediately. After the surgery, petitioner
underwent chemotherapy treatment until approximately December
1997.
On April 30, 1998, petitioner returned to the practice of
law part time.
BP Concessions, Inc.
Petitioner and Bernie Foster formed BP Concessions, Inc. (BP
Concessions), to sell goods and duty-free items at the Portland,
Oregon, airport. Mr. Foster and petitioner each held 50 percent
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