Eugene McClelland and Ione McClelland - Page 12

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          groceries, Mr. McClelland would sign a check with his name, and             
          she would fill out the amount paid.                                         
               With respect to petitioners’ 1997 return and Red Wing’s                
          Federal income tax return for its fiscal tax year ended October             
          31, 1997, Mr. McClelland kept and provided all financial records            
          and other information to Gary Kramer (Mr. Kramer), petitioners’             
          accountant.  Mr. Kramer completed petitioners’ joint 1997 Federal           
          income tax returns for the year in issue, as well as Red Wing’s             
          Federal income tax return for its fiscal tax year ended October             
          31, 1997.  Ms. McClelland did not review or sign Red Wing’s                 
          Federal income tax return for its fiscal tax year ended October             
          31, 1997, the only place the incorrect interest deduction                   
          appeared.                                                                   
               Ms. McClelland’s limited involvement in Red Wing’s financial           
          affairs included maintaining records that related to the number             
          of hours its employees worked and signing employee payroll                  
          checks.  Ms. McClelland provided this information to Mr. Kramer,            
          who used this information to calculate the withholding amounts              
          Red Wing needed to pay for various purposes.  Mr. Kramer                    
          instructed Ms. McClelland to write checks, each in a specific               
          amount for Red Wing’s withholding obligations.  Ms. McClelland              
          wrote checks in the instructed amounts and signed Mr.                       
          McClelland’s name.                                                          







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