Greta Ann Clifton - Page 8

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          signature card for the Orad account, and that they each signed a            
          partnership agreement.  Furthermore, petitioner notes that Orad             
          is Daro's name spelled backwards.                                           
               Although a partnership certificate was signed by both                  
          petitioner and Daro, the terms of the agreement relate                      
          exclusively to the Orad joint checking account.  The agreement is           
          a one-page document that addresses the relationship of                      
          petitioner, Daro, and the bank relative to the joint checking               
          account; the document does not address the signatories' business            
          relationship, if any.  Accordingly, we find that this agreement             
          alone does not demonstrate petitioner's and Daro's intent to                
          carry on a business as partners.  In addition, such an intent was           
          specifically denied by Daro.  Daro testified that she was not a             
          partner in Orad, that she had nothing to do with Orad, and that             
          petitioner operated Orad exclusively.  This testimony is                    
          supported by the record, since every check drawn on the Orad                
          account was endorsed by petitioner.  Thus, it appears that                  
          petitioner had exclusive control over Orad's income.                        
               Petitioner argues that both she and Daro received                      
          distributions from Orad, indicating a partnership relationship.             
          Specifically, petitioner noted that a $1,000 check drawn on the             
          Orad account was made out to Daro.  Respondent argues that this             
          payment to Daro was merely a reimbursement of one half of the               
          $2,000 contributed to Orad by Cena.  Daro corroborated                      
          respondent's argument, noting that Cena contributed $2,000 to               

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