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mobile homes on the ranch property, one of which served as her
personal residence.
Spirit Horse Ranch never issued any stock. Nor did Spirit
Horse Ranch ever file Federal corporate income tax returns or New
Mexico corporate franchise tax reports.
Spirit Horse Ranch maintained bank accounts with both United
New Mexico Bank and Ranchers State Bank. These bank accounts were
used to pay the expenses of operating the ranch. Both petitioner
and Mr. James were signatories on the bank accounts. Deposits into
the accounts came solely from petitioner. Occasionally, cash
disbursements were made from the bank accounts to petitioner and
Mr. James, although more frequently to Mr. James.
Petitioner maintained Spirit Horse Ranch's books and records.
In addition, she paid the bills and wrote the checks.
On July 29, 1988, petitioner conveyed title in her personal
residence in Albuquerque, New Mexico, to Spirit Horse Ranch. Title
to that property was conveyed back to petitioner on December 18,
1996. On February 24, 1997, the Albuquerque residence was again
conveyed to Spirit Horse Ranch.
Petitioner's Other Business Activities
During the years in issue, petitioner had ownership interests
in several entities other than Spirit Horse Ranch, including: Red
Carpet Realty, Inc., Red Barn Realty, Inc., Western Escrow Corp.,
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Last modified: May 25, 2011