AMW Investments, Inc. - Page 7

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               Around 1981, Mr. Mohney asked Janet Dingeman Fournier                  
          (Ms. Fournier) to serve as petitioner's president.  Ms. Fournier            
          served in this capacity until 1988.  As petitioner’s president,             
          Ms. Fournier had no meaningful responsibility other than to sign            
          tax returns and other documents on petitioner’s behalf.  Aside              
          from Ms. Fournier, petitioner had no employees.  Apart from the             
          use of company cars, Ms. Fournier received no compensation from             
          petitioner.                                                                 
               From 1974 through 1993, Ms. Fournier was also an employee of           
          Modern Bookkeeping Services, Inc. (MBS).  Mr. Mohney had formed             
          MBS to handle and centralize the bookkeeping and tax preparation            
          aspects of his businesses.  Elizabeth L. Scribner (Ms. Scribner)            
          was MBS’ president and general manager.  Thomas H. Tompkins                 
          (Mr. Tompkins) was MBS’ accountant, and he was responsible for              
          preparing petitioner's Federal income returns before the subject            
          years.  Lee J. Klein (Mr. Klein) provided legal services to MBS             
          and MBS’ clients.                                                           
               Petitioner's financial affairs were maintained at MBS’                 
          office in Durand, Michigan, and MBS maintained all of                       
          petitioner's files, including its bank accounts, cash receipts              
          journals, cash disbursements journals, and lease files.  MBS paid           
          petitioner's bills on behalf of it, and MBS prepared petitioner’s           
          financial statements.  MBS charged petitioner a fee of $1,000               
          per month for its bookkeeping services.                                     





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