Greta Ann Clifton - Page 5

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          presumably in her capacity as controller of Knappco.  Every check           
          drawn on the Orad account was endorsed by petitioner.  There was            
          no activity in the Orad account from August 1985 until May 1986,            
          when petitioner endorsed a check payable to herself for $1,300,             
          leaving a balance in the account of $13.69.  Thereafter, there              
          was no activity from June 1986 through January 1987, when the               
          account was closed by the bank for failure to pay service                   
          charges.                                                                    
               Orad did not file a Form 1065, U.S. Partnership Return of              
          Income, for tax year 1985.  Orad had gross receipts of $18,471 in           
          1985.  Petitioner included one half of Orad's gross receipts on             
          her 1985 Federal income tax return, or $9,235.  Daro, however,              
          did not include any of Orad's gross receipts on her 1985 Federal            
          income tax return.                                                          
               Petitioner's employment with Knappco terminated on August              
          27, 1985, when she was fired for allegedly stealing from Knappco.           
          Subsequently, petitioner was charged with two felony counts of              
          stealing by deceit money owned by Knappco.  Count 1 charged                 
          petitioner with issuing an unwarranted check in the amount of               
          $6,576 payable to Orad, and count 2 charged petitioner with                 
          issuing an unwarranted check in the amount of $3,405 payable to             
          Cena.  On June 6, 1986, petitioner pled guilty to both felony               
          counts of stealing by deceit from Knappco.                                  
               Petitioner testified that she owned three vehicles during              
          1985:  A 1965 Ford Mustang, a 1976 Chevrolet pickup truck                   




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