Joel Rappaport - Page 5

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               From July through December 2002, petitioner reduced the                
          amount of his business travel and primarily worked from home.               
          Petitioner used video conferencing to reduce stress and the need            
          to travel.  He worked an average of about 15 hours per week from            
          September to November 2002, about 20 hours per week from November           
          2002 to August 2003, about 10 to 15 hours per week from August              
          2003 to March 2004, about 30 hours per week from March to                   
          November 2004, and about 40 hours per week after November 2004.             
          Petitioner’s income was fairly stable throughout 2002-04.  As of            
          the date of trial, no one associated with JRC or RSC knew about             
          petitioner’s illness.                                                       
          D.   Income Tax Returns                                                     
               1.   Petitioner’s Tax Return for 2000                                  
               Stan Hester (Hester), a JRC employee, prepared petitioner’s            
          Form 1040, U.S. Individual Income Tax Return, for 2000.  JRC                
          employed Hester in 2001, 2002, and until October 2003.                      
               Petitioner signed his Federal income tax return for 2000 on            
          February 12, 2002, and untimely filed it on a date not stated in            
          the record.  Petitioner reported in that return that he had                 
          received wages of $160,000 from JRC.                                        
               2.   JRC’s and RSC’s Forms 1120S for 2001                              
               On January 3, 2003, petitioner filed Forms 1120S, U.S.                 
          Income Tax Return for an S Corporation, for 2001 for JRC and RSC.           







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