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in the farmhouse until she died in 1992. Petitioners remodeled
the farmhouse and furnished it as an office in 1994.
B. Barbara’s Gift Shop
1. General Business Activities
In 1994, petitioners operated Barbara’s Gift Shop and Barmes
Wholesale (Barbara’s Gift Shop), the principal place of business
of which was at 120 Main Street in Vincennes, Indiana. Barbara’s
Gift Shop was a wholesale and retail business. It is about 6�
miles from the Fritchton residence.
Petitioners each worked 7 days a week at Barbara’s Gift Shop
in 1994. Petitioner typically worked 14 hours per day, and Mrs.
Barmes typically worked 10 hours per day.
During 1994, about 90 percent of the time petitioner spent
working for Barbara’s Gift Shop was at 120 Main Street and about
10 percent was at the farmhouse in Fritchton. Petitioner had
some business meetings in the farmhouse, and Mrs. Barmes
occasionally did bookwork there. The farmhouse was not
petitioners’ primary place of business in 1994.
2. Petitioners’ Use of Automobiles
In 1994, petitioners bought a Cadillac for $39,215 and a
Corvette for $30,390. Petitioner primarily drove the Cadillac,
and Mrs. Barmes primarily drove the Corvette. During 1994, Mrs.
Barmes drove the Corvette to and from petitioners’ Fritchton
residence and 120 Main Street and for personal purposes. She
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