Maurice D. and Elinor Taylor - Page 4

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          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  All dollar amounts are rounded.                                 
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  The          
          stipulation of facts and the attached exhibits are incorporated             
          herein by this reference.                                                   
               Petitioners, husband and wife, resided in Baltimore, Maryland,         
          at the time they filed their petition.  They married in 1968 and            
          have three children.  For over 25 years, petitioner operated                
          several small businesses in the Baltimore area, including a                 
          grocery/convenience store.  During the period in issue, Mrs. Taylor         
          remained at home and took care of the children.                             
          Grocery/Convenience Store Business                                          
               In 1969 or 1970, petitioner began operating a "mom and pop"            
          grocery/convenience store under the name M&E, Inc. (Despite its             
          name, M&E, Inc., was a sole proprietorship of petitioner.)  Many of         
          petitioner's business records were in disarray.  Bills for                  
          business expenses were kept in boxes, and daily gross receipts were         
          recorded on a calendar.                                                     
               Mrs. Taylor began working in the store sometime in 1990 when           
          petitioner's criminal problems resulting from his check-kiting              
          scheme (discussed infra) overwhelmed him.  Following petitioner's           
          incarceration in January 1991, Mrs. Taylor ran the store with one           

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