Benjamin and Sallie Campfield - Page 6

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          the deposit.  When Williams conveyed this information to                    
          petitioner, petitioner said that it did not matter whether the              
          bank notified the IRS.                                                      
          Campfield Farm                                                              
               We will refer to the Route 3 property and the Route 21                 
          property collectively as the Campfield farm.  The Schedules F               
          attached to the petitioners' 1985 and 1986 Federal income tax               
          returns listed "Livestock Sales" as the principal product of the            
          Campfield farm.  Petitioner also sold melons in 1985 and 1986,              
          but the record does not indicate whether the melons were grown on           
          the Campfield farm.                                                         
               Several pieces of farm equipment were purchased for use on             
          the Campfield farm.  Leroy Campfield purchased the following                
          equipment from a farm equipment dealer in Sylvania, Georgia:                
                Equipment         Price         Date of Purchase                      
               A.C. Harrow       $1,800          Jan. 10, 1985                        
          Planter            1,400          Mar.  5, 1985                             
          Combine            6,500          Aug.  5, 1985                             
               The harrow, planter, and combine were each purchased from              
          the same farm equipment dealer, and the dealer prepared a                   
          separate invoice for each purchase.  Each of the three invoices             
          shows "Campfield Farm" as the purchaser.  Leroy Campfield                   
          purchased the harrow, planter, and combine on petitioner's                  
          behalf.                                                                     








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