Anthony G. and Shirley A. Olbres - Page 8

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                         Type of                                                      
               Bank      Account       Name of Account      Account Number            
           Kennebunk    Checking White Star Design,           66-910252               
                                   Inc.                                               
           Kennebunk    Checking White Star Design,           66-110152               
                                   Inc., Exhibit Design                               
                                   and Fabrication                                    

          (We shall refer to (1) Kennebunk checking account number 66-                
          910252 as the first Kennebunk White Star checking account and               
          (2) Kennebunk checking account number 66-110152 as the second               
          Kennebunk White Star checking account.)                                     
               Petitioners deposited Design Consultants' and/or White                 
          Star's receipts into the Indian Head business checking account,             
          the Indian Head business savings account, and various other bank            
          accounts that they maintained.7  Petitioners made the following             

          7  The parties stipulated that they deposited all "business                 
          checks" and receipts from "business clients" into either the                
          Indian Head business checking account or the Indian Head business           
          savings account.  We construe the references in those stipula-              
          tions to "business checks" and to receipts from "business cli-              
          ents" to mean receipts of Design Consultants and/or White Star              
          other than commissions that they received from businesses that              
          provided the auxiliary services.  As we construe those stipula-             
          tions, they are contrary to the record in this case.  Even if our           
          construction of those stipulations were incorrect in that the               
          references therein refer to all receipts of Design Consultants              
          and/or White Star, including commissions that they received,                
          those stipulations nonetheless would be contrary to the record in           
          this case.  That record shows, and we have found, that petition-            
          ers deposited both Design Consultants' and/or White Star's                  
          receipts from their clients and commission receipts into bank               
          accounts in addition to the Indian Head business checking account           
          and the Indian Head business savings account.  To illustrate,               
          petitioners deposited two checks from Numismatic Professionals,             
          Inc., into the Kennebunk personal savings account.  By way of               
                                                             (continued...)           




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