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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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