Ramon and Irma Ortiz - Page 5

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               Mrs. Ortiz was not involved in her husband's wholesale used            
          car business, R&X Auto Sales.                                               
          Mr. Ortiz and R&X Auto Sales                                                
               Mr. Ortiz was in the wholesale used car business and                   
          operated R&X Auto Sales.  Most of his business involved                     
          purchasing automobiles at auctions and then selling them to                 
          dealers in Puerto Rico.  This business required Mr. Ortiz to                
          handle checks in amounts as high as $30,000.  He occasionally               
          sold used cars to local individuals.  Mr. Ortiz deposited car               
          payments from individuals into petitioners' personal bank                   
          account.  He also deposited rent payments from Angels Transport             
          into petitioners' personal bank account during 1991 and 1992.               
          Angels Transport was a business that did mechanical work on some            
          of petitioners' property in Orlando.                                        
               Mr. Ortiz had a license that allowed him to purchase                   
          automobiles at auctions.  As part of his business, he allowed               
          other salesmen to purchase automobiles with his license.  Mr.               
          Ortiz charged the salesmen $100 for each car they purchased with            
          his license.  The salesmen would pay him for the price of the               
          automobiles purchased in addition to the $100 fees.  The money              
          received from these buyers was included by respondent in                    
          determining the income of Mr. Ortiz for 1991 and 1992, and the              
          price paid for the cars purchased by the buyers was included in             
          cost of goods sold.                                                         






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