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FINDINGS OF FACT
Some of the facts have been stipulated. The stipulated
facts and the accompanying exhibits are incorporated into our
findings by this reference. Petitioner, Greta Ann Clifton,
resided in Albuquerque, New Mexico, on the date the petition was
filed.
Petitioner is an accountant. During 1985, petitioner was
the Controller of Knappco, Inc. (Knappco), a company located in
Kansas City, Missouri. While working for Knappco, petitioner
lived at 599 Highway 224, Wellington, Missouri.
While petitioner was working at Knappco, Cheryl Daro (Daro)
babysat petitioner's child. During April of 1985, petitioner and
Daro formed Cena Enterprises (Cena). Cena was formed to provide
computer data entry services for Knappco. Cena was licensed to
do business in Napoleon, Missouri. Petitioner and Daro opened a
joint checking account at Napoleon Bank, Napoleon, Missouri, in
the name of Cena (Cena account). During 1985, both petitioner
and Daro made deposits to and withdrawals from the Cena account.
Petitioner and Daro, doing business as Cena, prepared
letters, mailing lists, and inventory tables for Knappco. More
specifically, petitioner would bring a computer to Daro's home in
Napoleon, Missouri, and Daro would type the letters, mailing
lists, etc. while petitioner was working at Knappco.
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