Neil J. Christal, II & Kathryn E. Christal - Page 8

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          $543.45.  The receipt listed Mr. Christal, and not United                   
          Sovereigns, as the customer.  The automobile repaired was the               
          Caravan, and the receipt was stamped "paid" with check 2239 noted           
          on the receipt.  Mrs. Christal signed the receipt.                          
               In 1992, United Sovereigns paid for automobile work                    
          completed on the Caravan in the amount of $429.05 with United               
          Sovereigns' check 3103.  United Sovereigns claimed the $429.05              
          spent on the Caravan as a business expense.                                 
               In 1992, United Sovereigns claimed $559.97 it paid to                  
          Competition Motors as an automobile expense.  The Competition               
          Motor receipt listed Mr. Christal, and not United Sovereigns, as            
          the customer.                                                               
               On January 10, 1991, Mr. Christal signed a Pioneer Health              
          insurance application.  In 1992, United Sovereigns paid for the             
          Pioneer Health insurance which covered petitioners and their                
          children, and it deducted the policy's full cost on its 1992 tax            
          return.  United Sovereigns did not pay health insurance premiums            
          for Ms. Menon or Ms. Johanson.                                              
               In 1992, United Sovereigns paid for a Price Club membership.           
          Mr. and Mrs. Christal's names were on the Price Club application.           
          No other names were on the Price Club application.  United                  
          Sovereigns claimed the Price Club membership fee as a supply.               
               In 1992, United Sovereigns paid for a Reader's Digest                  
          subscription for Mrs. Christal and claimed the subscription as a            





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