J. Jean Moore - Page 2

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               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code as amended, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           

                                  FINDINGS OF FACT                                    
               This case was submitted under Rule 122, but other than                 
          establishing the residence of petitioner in San Diego,                      
          California, the stipulation of the parties relates only to                  
               During the 1990s and until at least the end of 2003,                   
          petitioner solely owned and operated, through a limited liability           
          company (LLC), an eldercare business in California and in                   
               In addition to the income petitioner received relating to              
          the eldercare business, petitioner received rental income                   
          relating to residential and commercial real property that                   
          petitioner owned in California and in Oregon.                               
               In 2001, after an audit and a criminal tax investigation by            
          respondent relating to petitioner’s individual Federal income               
          taxes for 1992 through 1995, petitioner was charged with and was            
          convicted on several counts of tax evasion.  As a condition of              

               1  References in our findings of fact to ownership, and to             
          transfers, of real property and of other assets are not intended            
          to constitute ultimate findings of fact as to the true legal and            
          equitable ownership of the real property and other assets                   
          involved in this case.                                                      

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