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owned, though it never did any business, by * * * [Mowrey’s]
father.” Crestmark has never had any office outside the
individual petitioners’ personal residence, nor a telephone
number other than the individual petitioners’.
On November 17, 1993, Boehm deposited $102,955 into an
account established in the name of Crestmark at NationsBank of
Texas. Prior to this deposit, the account had a balance of
$34.65. This was the only account in the name of Crestmark
during 1993. The November 1993 deposit was the only money
received by Crestmark during its fiscal year ended July 31, 1994.
Petitioners allege that the $102,955 deposited into
Crestmark’s account represented payment for services performed
for Mowrey by Boehm, in his capacity as sole employee of
Crestmark. No written contract existed between Crestmark and
Mowrey. Neither Boehm nor Crestmark at any time provided Mowrey
with any documents or records stating what services were
performed, the date or time any services were performed, or who
performed any services.
On their Schedule A attached to their 1993 joint Federal
income tax return, petitioners claimed a deduction of $103,0562
2 The record contains no explanation of the apparent
discrepancy between the $102,955 November 1993 deposit, and the
$103,056 that petitioners have claimed as a deduction.
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