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FINDINGS OF FACT
Some of the facts and certain exhibits have been stipulated.
The parties’ stipulations of fact are incorporated herein by
reference and are found as facts. Petitioners resided in Rock
Hill, South Carolina, at the time the petition was filed.
Petitioners are Frank H. Black (Mr. Black) and Marla C.
Black (Mrs. Black). Petitioners were married throughout all
relevant periods.
Mr. Black graduated from Michigan State University in 1969
with a Bachelor of Science degree, majoring in sociology and
minoring in religion. He was self-employed during 1991 and 1992
as a licensed stockbroker, investment consultant, and insurance
agent.
On July 1, 1990, Mr. Black started his own business, Frank
Black d/b/a Robert Thomas Securities, which continued to operate
throughout 1991 and 1992. On May 18, 1992, Mr. Black formed a
North Carolina “C-Corporation”, Frank Black, Inc. Respondent has
not conducted an examination of Frank Black, Inc., for the
taxable year 1992.
Mr. Black maintained his own books and records for 1991 and
1992, but failed to maintain complete and accurate books and
records of income and expenses for either taxable year.
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