Clyde E. Owens and Marie W. Owens - Page 6

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          Chick competed with a McDonalds and a Hardees.  Mrs. Owens                  
          employed students to work part time, 10 to 15 hours a week.                 
               Mrs. Owens wrote checks for utilities in 1989 totaling                 
          $16,346.09 on Burger Chick's account.  Her children wrote two               
          checks totaling $2,409.83.                                                  
               The combined gross income of Big O Truck Stop, Big O                   
          Barbecue, and Burger Chick was between $500,000 and $1 million er           
          year in the years in issue.                                                 
               5.   Petitioners' Supplies                                             
               Most of petitioners' suppliers deliver once a week.  Mr. and           
          Mrs. Owens do not have much storage room at the businesses.  They           
          sometimes used their cars to buy supplies and food for their                
          businesses.  Walker Meat in Carrolton delivers meat to                      
          petitioners once or twice a year.  Petitioners go to Walker Meat            
          to get meat at other times.  They go to the grocery store to get            
          items such as cheese and mayonnaise when necessary.  They usually           
          pay cash for these items.  Ms. Feltrinelli sometimes used her car           
          to go to Sam's Club to get pork and barbecue for Big O Barbecue.            
          C.   Petitioners' Income Tax Returns                                        
               Robert H. King (King), a self-employed accountant, prepared            
          Mr. and Mrs. Owens' and Ms. Feltrinelli's 1989 and 1990 income              
          tax returns.  The Owens gave King the information he used to                
          prepare their returns.  On their Schedules C for 1989 and 1990,             
          Mr. and Mrs. Owens reported that their businesses were "Burger              
          Chick - Vineyard - Towing Service".  They did not refer to Big O            

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