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account). Mr. Jones deposited his Brown & Root paychecks into
the household account. Petitioner wrote all but 2 of 340 checks
drawn on the household account in 1981, paying the monthly and
regular household bills, as well as bills totaling $10,000 for
improvements to their home.
After the Joneses returned from England during 1977,
petitioner also handled the family savings account, transferring
between the checking account and the savings account the
following amounts on the following dates: $2,500 on April 25,
1981, $1,500 on May 13, 1981, and $1,500 on June 8, 1981.
Petitioner opened most of the mail that came to their house,
except for Mr. Jones' important, personal mail. As a result of
opening the mail, petitioner discovered things that caused her to
question Mr. Jones about his financial affairs.
Two or three years after returning from England, petitioner
started a small dress shop in Sealy, Texas. She opened the dress
shop without any prior experience in either retail sales or
keeping books. After she opened the dress shop, petitioner hired
others to perform bookkeeping and accounting services because she
had no interest or expertise in bookkeeping or accounting and she
knew how important it was to keep receipts and other records for
that purpose. Emma Rice, petitioner's daughter-in-law, did most
of the bookkeeping in the early years of the business, but
petitioner subsequently hired an accountant named Jack Singleton
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