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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
exhibits.
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
Oregon.1
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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