James O. Jondahl - Page 15

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              Taxman occasionally accepted equipment from one of its                  
         clients, Site on Sound Car and Home Electronics (Site on Sound),             
         in lieu of payment on Site on Sound’s balance due.  In May 1991,             
         petitioner received a home stereo system as partial payment of               
         Site on Sound’s balance due.  The stereo was valued at $509.                 
         Petitioner gave the home stereo system to his girlfriend, Melodie            
         Lane.  He did not report the $509 as income on his personal tax              
         return for 1991.  Ms. Lane worked in an office of Taxman Express,            
         a subsidiary of WFIC, for 1 month in early 1992.  Taxman Express             
         was a business opened by petitioner in 1991 in order to prepare              
         and e-file tax returns for walk-in customers.  Ms. Lane was never            
         employed by Taxman.                                                          
              C.  1992                                                                
              On October 1, 1990, petitioner formed Western Realty                    
         Partners, L.P.-I (WRP).  WFIC was the general partner of WRP and             
         held a greater-than-95-percent interest in WRP.  On October 5,               
         1990, Valis R. Garceau, a client of petitioner’s and Taxman’s,               
         gave petitioner $10,000 to purchase rental real estate on her                
         behalf.  Petitioner deposited the $10,000 in WFIC’s trust                    
         account.  On the same day, $10,000 was withdrawn from WFIC’s                 
         trust account by check payable to WRP.  A memo on the check read             
         “V. Garceau CD”.  Petitioner does not dispute that the check was             
         used to purchase a $10,000 CD.  On May 6, 1991, WRP liquidated               
         the CD and deposited the funds, $10,418.89, into a new money                 






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