Estate of Birnie M. Davenport, Deceased, Patricia L. Vestal, Personal Representative - Page 11

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            joint ownership agreement, on the Federal and State income tax                               
            returns which Birnie prepared for herself and her sister, Birnie                             
            reported one-half of all investment income as being hers and one-                            
            half as being Elizabeth's.                                                                   
                  Birnie and Elizabeth maintained an office in their home from                           
            which they conducted their investment activities.  Birnie                                    
            reported one-half of the allowable deductions with respect to                                
            such office on her own Federal income tax returns and one-half on                            
            Elizabeth's Federal income tax returns.  After 1965, the Federal                             
            and State income tax returns of Birnie and Elizabeth were                                    
            prepared by Corrine Childs, C.P.A., a licensed attorney, tax                                 
            adviser, and tax return preparer.  Birnie and Elizabeth informed                             
            Ms. Childs of their joint ownership agreement and of the manner                              
            in which they had been reporting their income, deductions, gains,                            
            and losses with respect to their investments.  On the returns                                
            which Ms. Childs subsequently prepared for Birnie and Elizabeth,                             
            income, deductions, gains, and losses with respect to investments                            
            were reported one-half on the return of Birnie and one-half on                               
            the return of Elizabeth.                                                                     
                  Throughout the period of their agreement, Birnie and                                   
            Elizabeth filed their Federal and State income tax returns                                   
            reporting their wage earnings separately and sharing equally in                              
            the profits and losses resulting from their various investments.                             
            Several of the Federal income tax returns filed by Birnie and                                
            Elizabeth during the period 1965 through 1979 were audited.  Upon                            




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