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Minnesota (First Bank). During each of the years at issue,
petitioner used petitioner’s checking account as his personal
account, making personal deposits into, and writing personal
checks on, that account. Norwest Realty has never filed a tax
return.
Weavewood, Inc.
In 1947, petitioner’s father, Howard Thompson, Sr. (Mr.
Thompson), who died in 1991, founded Weavewood, Inc. (Weavewood),
a closely held corporation located in Minneapolis, Minnesota
(Minneapolis). At all relevant times, Weavewood engaged in the
business of manufacturing wood products, such as bowls and trays.
At such times, Weavewood maintained a checking account
(Weavewood’s checking account) at Norwest Bank in Minneapolis
(Norwest Bank-Minneapolis).
Beginning in 1947 and continuing throughout each of the
years at issue, various members of petitioner’s family managed
Weavewood. From August 1995 until July 12, 1996, petitioner
served as president, secretary, treasurer, and chairman of the
board of directors (board) of Weavewood. Weavewood did not
compensate petitioner for serving in those positions.
Weavewood’s Company Vehicle
On February 16, 1996, petitioner signed a $10,000 check
(Weavewood’s February 16, 1996 check) payable to an individual
named Paul Robinson (Mr. Robinson) and drawn on Weavewood’s
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