Janice L. Morris - Page 8

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          signed at least one check drawn on that account.  However, during           
          those years, Mr. Morris controlled the affairs of Meadows, and              
          petitioner was not involved in the day-to-day operations of that            
          corporation and was not in a position to know how much income               
          Meadows generated from those operations.                                    
               In addition to the Meadows account at the National Bank of             
          Monticello, Mr. Morris maintained a checking account in the name            
          of Meadows at the Champaign National Bank (Meadows account at the           
          Champaign National Bank) on which he and petitioner were signato-           
          ries and into which he deposited certain of the embezzled funds.            
               During 1988 and 1989, Meadows sold to unrelated persons the            
          sand and gravel located in the gravel pit and deposited the                 
          proceeds from those sales into the Meadows account at the Na-               
          tional Bank of Monticello.                                                  
               Petitioner visited the Illinois land during 1988 and 1989,             
          observed children playing around the gravel pit, and became                 
          concerned that those children might sustain injuries for which              
          Meadows might be held liable.  She therefore suggested that a               
          liability insurance policy be obtained to cover the Illinois                
          land.  During 1989, petitioner signed an insurance application              
          for such a policy in which she indicated that the applicant's               
          primary occupation was "Accountant".  Petitioner signed a check             
          for $100 drawn on the Meadows account at the Champaign National             
          Bank that was used to pay a premium for that policy.                        
               The Form 1120S that Meadows filed for 1988 was signed by Mr.           




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