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Petitioner and her husband were members of the Orlando Opera
Guild.
Petitioner's husband works at his surgical practice on an
average of more than 70 hours per week. During 1992, petitioner
worked with her husband as a medical transcriber, earning $11,700
in wages. Petitioner graduated from St. Louis University in 1960
with a degree in medical records administration. Because she had
more free time, petitioner maintained the family's checking
account and handled the bills for all of the household expenses.
She usually retrieved the mail because she arrived home earlier
than her husband.
Petitioner oversees the operation of JCB Construction, Inc.
(JCB), an S corporation of which she has been the sole owner
since its creation in 1987. As secretary-treasurer of JCB,
petitioner maintains its books and records, keeps track of income
and expenditures, handles payroll and personnel responsibilities,
writes checks for materials and supplies, and collects
information for the preparation of JCB's tax returns. JCB filed
Forms 1120S with the Internal Revenue Service (IRS) from 1988
through 1996, and FICA and FUTA returns since at least 1989. The
gains or losses of JCB were reported on petitioners' Federal
income tax returns for the year at issue and in prior years.
B.G. Enterprises, Inc. (BGE) was an S corporation owned by
petitioner's husband and Thomas George. BGE was engaged in the
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