Patti Ann Ollestad - Page 4

                                        - 4 -                                         

               During the years at issue, Mr. Thompson worked for Dan                 
          Thompson Trucking (Trucking),3 a partnership he had formed with             
          his father Harry Thompson.  Trucking employed several truck                 
          drivers; however, Trucking did not employ a bookkeeper or a                 
          secretary.  Mr. Thompson maintained the books and records for               
          Trucking.  Trucking's business office was not located in the                
          marital home, and Mr. Thompson did not conduct business in the              
          marital home.  Petitioner did not work or perform services for              
          Trucking and did not help generate income for the business.                 
               Petitioner and Mr. Thompson had one checking account.  This            
          account was used for business and personal purposes.  Petitioner            
          was allowed to write checks or make deposits only with Mr.                  
          Thompson's permission.  Petitioner wrote checks for groceries or            
          clothes for the children.  Petitioner never purchased, and was              
          not given, jewelry or furs.  On occasion, Mr. Thompson asked                
          petitioner to write checks between the amounts of $100 and $400             
          for "cash".  Petitioner gave the money from these checks to Mr.             
          Thompson, who used the money to pay truck drivers for fuel and              
          for various personal expenses.  Sometimes, Mr. Thompson requested           
          that petitioner make deposits to the checking account.                      
          Petitioner did not know the source of the funds she deposited.              

          3         In view of the manner in which both parties presented             
          this case, we must assume that National Cartage Co. is either a             
          former name of Trucking or perhaps a "d.b.a.".  Thus, we will               
          regard respondent's determination in the notice of deficiency as            
          relating to Trucking.                                                       

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