Albert M. Graham and Martha A. Graham - Page 6

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          lien relating to his 1956 Mercedes Benz in favor of his friend              
          Lee Cogan (Cogan), even though he did not owe Cogan money; (2) a            
          deed of trust secured by their residence in favor of petitioner’s           
          office manager, Charlene Edgar (Edgar), purportedly securing a              
          $164,465.06 debt, even though petitioners did not owe Edgar any             
          money; (3) a deed of trust secured by petitioner’s law office               
          building purportedly securing a $50,000 debt owed to petitioner’s           
          accountant, James O’Leary (O’Leary), when petitioner owed no                
          money to O’Leary; and (4) a deed of trust in favor of Lewellen              
          for $38,000, when petitioner owed Lewellen $8,000-$10,000 in                
          unpaid accounting fees.  Edgar prepared the deeds of trust, and             
          Sieveke notarized them.                                                     
          C.   Petitioner’s Law Practice                                              
               1. Organization of Petitioner’s Law Office                             
               Petitioner was a deputy district attorney in Orange County,            
          California from 1969 to February 1972.  He has specialized in               
          family law since 1983.  Petitioner was a sole practitioner in               
          Santa Ana, California, during the years in issue.  Petitioner’s             
          law office is located in a one-story building that he owns.                 
               Edgar began working as petitioner’s office manager around              
          1982.  Edgar took over the bookkeeping and accounting for                   
          petitioner's law practice in 1991.  From 1995 to early February             
          1999, Edgar was responsible for the day-to-day management of the            
          office.  She was primarily responsible for client billing and               






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