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FINDINGS OF FACT
A. Petitioners
Mr. and Mrs. Pert lived in Palm Harbor, Florida, when they
filed their petitions.
B. Transferor Timothy C. Riffe
Mr. Riffe died on February 11, 1991. Decedent and Mrs. Pert
had timely filed joint Federal individual income tax returns for
1986, 1987, 1988, and 1989.
1. Mr. Riffe's Businesses
During 1986, 1987, 1988, and 1989, Mr. Riffe owned
businesses known as West Coast Pest Control and West Coast
Florida Pressure Cleaning. West Coast Pest Control sprayed
pesticides on lawns. West Coast Florida Pressure Cleaning used a
pressure cleaning process to wash cars for car dealers. Mr.
Riffe owned the car wash business before he married Mrs. Pert.
Mrs. Pert worked long hours in both businesses and ran the car
wash business. Mr. Riffe was the sole owner of occupational
licenses for both of these businesses. He had sole signature
authority over the bank accounts for the businesses.
Mr. Riffe's and Mrs. Pert's joint income tax returns for
1986, 1987, 1988, and 1989, include Schedules C for the car wash
business in Mr. Riffe's name. They reported on their 1988 return
that the business paid Mrs. Pert $13,800 in wages. Their 1989
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