Robert E. and Carloyn S. Holmes - Page 22

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             Mr. Jackson's advice, petitioners also began reporting the               
             losses from their farming activities on RC's partnership                 
             tax returns.                                                             
                  Petitioners maintained a checking account with the                  
             Chemical Bank-South (Chemical) for their tennis villa,                   
             resort villa, and farming activities.  This bank account                 
             was separate from petitioners' personal bank accounts.                   
             Petitioners typically paid expenses incurred in their                    
             farming activity with checks drawn on the Chemical account,              
             but it is not clear from the record when this practice                   
             began.  These checks were imprinted with the name "R/C                   
             ENTERPRISES" and the address of petitioners' personal                    
             residence.  Petitioners also periodically paid expenses                  
             related to their farming activity with checks drawn on                   
             their personal checking account.                                         
                  Mrs. Holmes was primarily responsible for keeping                   
             the books and writing checks to pay expenses relating                    
             to petitioners' business and farming activities.  When                   
             petitioners received a bill, petitioner would typically                  
             inspect the bill and write "labor", "machinery", or some                 
             other designation on the portion to be retained for                      
             petitioners' records.  He would then give the bill to                    
             Mrs. Holmes to pay and record.  Mrs. Holmes would then                   
             allocate the expense to one of petitioners' business                     





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