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income for 1983 is community property affects those determina-
tions for that year.2
FINDINGS OF FACT
Many of the facts are deemed admitted pursuant to Rule
90(c).3
Each petitioner resided in California at the time the
respective petitions in these cases were filed.
For a number of years prior to and during the years at
issue, Ms. Drummond, a college graduate and a certified manage-
ment accountant, was employed by American Business College (ABC),
a vocational college located in San Diego, California, that was
owned and operated by E.D.U.C., Inc. (E.D.U.C.). Colonel Haller
was the stockholder and chief executive officer of E.D.U.C.
For a number of years prior to 1983, Ms. Drummond worked as
a supervisor in the business office and the bookkeeping depart-
ment of ABC. During the years at issue, Ms. Drummond was the
bookkeeper and the comptroller of ABC and vice president of
E.D.U.C. During those years, Colonel Haller did not visit the
business office of ABC on a daily basis. Instead, he relied on
2 Respondent's concession for 1983 and our holdings in Mr.
Drummond's case at docket No. 26077-96 will require a computation
in that case under Rule 155.
3 Unless otherwise indicated, our Findings of Fact and
Opinion pertain to the years at issue.
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