Glenyce R. Peterson - Page 5

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          $6,336.96 on February 1, 1990 and $4,934.95 on January 3, 1991.             
          Between June 13, 1990 and January 2, 1991, petitioner and Mr.               
          Peterson wrote $31,476.39 worth of checks against the Menomonie             
          account.  Of this amount, petitioner wrote checks totaling                  
          $8,519.84, and Mr. Peterson wrote checks totaling $4,728.07.  An            
          employee named Jeff White, who worked for the Petersons, wrote              
          checks against the account totaling $11,699.19.2  The records               
          from the Menomonie account indicate that the account had a                  
          balance of $20.90 on March 6, 1990 and $3,892.79 on December 31,            
          1990.  Petitioner managed the account records for both of these             
          accounts.                                                                   
               Mr. Peterson prepared the couple's 1990 Federal income tax             
          return.  That return reflects the following amounts of gross                
          income:                                                                     
               Wages               $64,258                                            
               Interest            1,091                                              
               Other gains         5,280                                              
               Gross rents         15,982                                             
               Gross farm income    3,570                                             
                    total          $90,181                                            
          The couple's 1990 return also reflects the following tax                    
          withholdings and expenditures:                                              
               Federal income tax withholdings         $ 10,458.00                    
               Social Security tax withholdings        4,962.43                       
               State tax withholdings                  4,082.18                       
               Rental expenses                         11,465.00                      
               Farm expenses                           65,219.00                      
               Depreciable assets purchased            95,319.86                      
                    total                              $191,506.47                    

               2It is unclear from the record who wrote the remaining                 
          $6,529.29 worth of checks.                                                  



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