Joel Rappaport - Page 4

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          before the IRS during those years.  RSC timely filed employment             
          tax returns for 2001-04.  Petitioner signed all of those                    
          employment tax returns.  RSC paid JRC $192,500 for services that            
          petitioner performed in 2001.                                               
               2.   Consulting for Business, Inc.                                     
               Petitioner’s wife and two children owned a business called             
          Consulting for Business, Inc. (CFB).3  CFB provides marketing               
          activities (e.g., direct mail services) to JRC and RSC.                     
          Petitioner has been president of CFB since its inception around             
          C.   Petitioner’s Illness                                                   
               In June 2002, petitioner sought treatment at the Mayo Clinic           
          for pain in his left leg and his back.  The pain worsened in July           
          2002.  He had difficulty walking in August 2002.  Petitioner was            
          soon diagnosed with multiple myeloma, which he was told is an               
          incurable blood disorder.  He received radiation therapy 22 times           
          over a 45-day period beginning in September 2002.  Petitioner               
          changed medications several times because he had adverse                    
          reactions.  From August 2002 to April 2004, the medication                  
          affected petitioner’s personality and caused petitioner to have             
          difficulty sleeping, bending, walking, and traveling.                       

               3  Apparently petitioner was not a shareholder of CFB.  Exh.           
          18-P, General Ledger for Consultants for Business, Inc., refers             
          to petitioner’s wife, but not petitioner, as a CFB shareholder.             

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