Eddie M. and Cynthia L. Chandler - Page 4

                                   - NEXTRECORD  -                                    
               Petitioner Cynthia L. Chandler (Mrs. Chandler) is a college            
          graduate and a registered nurse by profession.  In 1989 and for             
          part of 1990, she worked part time as a bookkeeper for Mike's               
          Video in Anniston, Alabama, and received nonemployee compensation           
          in return for her services.  Mrs. Chandler terminated her                   
          business relationship with Mike's Video in 1990.                            
               Petitioners reported income on their 1989 and 1990 income              
          tax returns as follows:                                                     
                                                  1989           1990                 
          Wages (petitioner)                   $20,907           $245                 
          Interest                                 749            395                 
          Schedule C (petitioner)                                                     
          (1) bulldozer work/digging                                                  
                    net profit                                  6,267                 
          (2) sale of wood products                                                   
                    net profit                                  2,910                 
          (3) sale of melons                                                          
                    net profit                                  1,500                 
          Unemployment compensation                145            ---                 
          Bookkeeping income (Mrs. Chandler)     1,800            900                 
           23,601         12,217                                                      

               During 1989, petitioners maintained at least three accounts            
          with Family Savings Federal Credit Union.  During 1990, they                
          maintained at least four such accounts.  These accounts included            
          share draft accounts.  Only Mrs. Chandler wrote checks on the               
          share draft accounts.  Mrs. Chandler did not retain petitioners'            
          bank statements and the carbon copies of their checks; rather,              
          she discarded them after the checks had cleared their accounts.             








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