Greta Ann Clifton - Page 4

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               Cena did not file a Form 1065, U.S. Partnership Return of              
          Income, for the year 1985.  Cena had gross receipts of $24,463              
          for the year 1985.  Petitioner and Daro each reported $12,216 of            
          Cena's gross receipts on their 1985 individual Federal income tax           
               On May 9, 1985, petitioner and Daro opened a joint bank                
          account at Norbank, North Kansas City, Missouri (Norbank), in the           
          name of petitioner and Daro doing business as "Orad Associates"             
          (Orad account and Orad).  The signature cards for the Orad                  
          account bear the signatures of both petitioner and Daro.                    
          Included in the records of the Norbank account was a document               
          entitled "Partnership Certificate" for the "General Co-                     
          partnership known as Orad Associates."                                      
               Although Daro signed the aforementioned partnership                    
          certificate, she testified that she was not a partner in Orad.              
          Furthermore, she testified that she had nothing to do with Orad,            
          and that petitioner operated Orad exclusively.                              
               During 1985, $20,971 was deposited into the Orad account.              
          With the exception of a $500 deposit (which was made from                   
          petitioner's personal bank account at Norbank) and a $2,000                 
          deposit (which was made by Cena), all the remaining deposits into           
          the Orad account were from Knappco, payable to Orad.  The checks            
          from Knappco, payable to Orad, were all signed by petitioner,               

          3  The record does not establish why petitioner and Daro included           
          only $12,216 each on their returns, when one-half of Cena's                 
          $24,463 of gross receipts is $12,231.50.                                    

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