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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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