S. Paul and Patricia J. Dubose - Page 5

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          in payment of the corporation’s interest in Kywood.  That check             
          was also deposited into the account of the Church of the New Age.           
               On September 25, 1987, Kentucky Wood issued a check payable            
          to Mrs. Dubose in the amount of $61,319.61 as payment for 2,693             
          shares of her stock in Kentucky Wood.  On October 29, 1987, at              
          petitioner’s direction, that check was deposited into a new                 
          interest-bearing checking account in the name of Earth Harmony              
          Church.  Also on September 25, 1987, a check in the amount of               
          $17,773.80 was issued by Kentucky Wood to Mrs. Dubose in payment            
          of her remaining partnership interest in Kywood.  This check was            
          also deposited into the Earth Harmony Church account.                       
               On April 22, 1988, petitioners opened a checking account in            
          the name of the Church of the Golden Rule.  In 1988 and 1989,               
          petitioners transferred $275,000 from the bank account of the               
          Church of the New Age to the bank account of the Church of the              
          Golden Rule.  Petitioners had signature authority on the Church             
          of the Golden Rule account and used the funds in that account to            
          make personal investments and to pay personal expenses.                     
               Petitioner’s purpose in depositing funds into bank accounts            
          in the name of the Church of the New Age, the Earth Harmony                 
          Church, and the Church of the Golden Rule was to avoid income tax           
          on the sale of petitioners’ interests in Kentucky Wood                      
          and in Kywood and to avoid paying tax on income earned on the               
          proceeds of sale.  To further that purpose, petitioner made                 





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