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degree with honors from the University of California Riverside.
In December 1983, petitioner received a juris doctor degree from
Western State University College of Law. On June 13, 1984,
petitioner was admitted to the California bar.
Petitioner, Mr. Ludlow, and Ludlow & Price
From the early 1960s until 1985, Thomas H. Ludlow practiced
law as a sole practitioner. In September 1985, Mr. Ludlow began
practicing law with petitioner as “Ludlow & Price” (the law
firm). During the years in issue the law firm was located in
Corona, California, at either 212 or 812 East Grand Boulevard.
In January 1986, petitioner and Mr. Ludlow married. During
the years in issue, petitioner and Mr. Ludlow were married and
lived together at 1860 Kellogg Avenue, Corona, California.
During the years in issue, petitioner and Mr. Ludlow filed joint
Federal income tax returns, and they reported their law firm
income, expenses, and profits on a Schedule C.
Mr. Ludlow’s Health
Starting in 1982 or 1983, Mr. Ludlow began having heart
problems. In late 1985 or early 1986, Mr. Ludlow had a massive
heart attack. In 1993, Mr. Ludlow died.
Hiring of Mr. Reiter
In 1988, the law firm fired its bookkeeper/office manager
for alleged embezzlement. At this time, petitioner and Mr.
Ludlow consulted with Marvin Reiter, a C.P.A., who had assisted
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