Dwight L. McKenna and Beverly S. McKenna - Page 12

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                  The operation of the newspaper was an expensive venture,                              
            which was financed by petitioner.  In 1987 the newspaper had a                              
            net loss of $8,184 and in 1988 it had a net profit of $6,046.                               
            Mrs. McKenna was able to operate the newspaper and continue to                              
            maintain her lifestyle, household, and children's education                                 
            because of petitioner's medical practice.                                                   
                  Mr. Bruno and his accounting firm performed full accounting                           
            services for Mrs. McKenna's newspaper business.  This service                               
            included a compilation of the accounting records, general ledger,                           
            and annual financial statements.  For 1988, the compilation work                            
            was performed by Marie Walters.                                                             
                  When Mrs. McKenna started her newspaper in 1985, she decided                          
            to have full accounting services performed.  This decision was                              
            made because she did not feel comfortable handling this aspect of                           
            the business by herself.  Once Mrs. McKenna turned the newspaper                            
            records over to Bruno and Tervalon, she relied upon the                                     
            accounting firm to process the records properly.                                            
                  When Mrs. McKenna received revenues from the sale of                                  
            advertisements in her newspaper, she deposited those revenues                               
            into her bank account.  By giving her bank statements to Bruno                              
            and Tervalon, it was her belief that Mr. Bruno's firm had                                   
            sufficient information to determine the newspaper's income.                                 









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