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salesmen, a separate reception area, and a larger tag room; the
former kitchen/tag room was made into a break room.
In approximately 1984, petitioners bought a Tandy computer
for the nursery. Due to the computer's limited capabilities,
petitioners decided to use it only for billing the nursery's more
detailed and frequent accounts, generally those of the chain
store customers. Petitioners continued the use of the previous
invoice system for the remaining customers; these orders were not
recorded on the computer. The two types of invoices had separate
numbering sequences. Mrs. Gandy established two ledgers, one for
each type of invoice. In 1985, petitioners bought an IBM
computer with a new accounting software package.
During 1985 through a portion of 1987, Mrs. Gandy worked in
the business office of the nursery on a daily basis. She was in
charge of the office and trained the employees who worked there.
Sometime during 1987, Mrs. Gandy quit working in the office. Ann
Dozier (Dozier) became the office manager after Mrs. Gandy left.
Mr. Gandy spent very little time in the office, spending most of
his time in the field. Many of the office employees were either
friends or relatives of petitioners or of each other.
During the years in issue, petitioners maintained a business
bank account at the First State Bank of Van styled "Dennis Gandy
Nursery" (account No. 01-0118-8), which was the business bank
account for the nursery. During 1989, Mr. Gandy maintained a
business bank account at the First National Bank of Canton styled
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