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Petitioner married Lori J. Jondahl (Lori) on August 11,
1983. In 1986, petitioner and Lori bought a house in Moorhead,
Minnesota, in which they lived until June 1990. In June 1990,
petitioner moved out of the Moorhead house and into an apartment
in West Fargo, North Dakota, where he lived until December 31,
1993. On July 9, 1991, petitioner and Lori were granted a
divorce. Lori was granted custody of the couple’s daughter. On
October 30, 1993, petitioner married Mary Lee Jondahl (Mary).
Petitioner and Mary are still married.
I. Petitioner’s Business Activities
A. Petitioner’s Tax Preparation Business
In January 1976, petitioner began preparing Federal and
State tax returns as a sole proprietorship under the name Jondahl
Tax Service, and later under the name Jondahl Financial Services
(JFS). In 1978, petitioner became an Internal Revenue Service
(IRS) enrolled agent authorized to practice before the IRS.
B. Taxman
In October 1986, Taxman was incorporated by David Garaas,
petitioner’s attorney. Taxman’s initial directors were Tony
Baasch, an associate of petitioner’s, and Gerald Owen Jondahl
(Mr. Jondahl), petitioner’s father. At Taxman’s first board of
directors meeting, Mr. Jondahl was elected president, Mr. Baasch
was elected vice president, and Gladys Jondahl (Mrs. Jondahl),
petitioner’s mother, was elected secretary and treasurer.
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