Harvey J. Davis and Patricia A. Davis - Page 4

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          buying it.  He believed that it was making money and had a great            
          location.  Petitioner has operated it as a Schedule C business              
          since 1994.  Petitioner bought Midwest Truck Stop because he was            
          looking for a good business for his son, Gaylan, to operate.                
          They also had considered buying convenience stores, but the                 
          stores were not making much money.  Gaylan has managed Midwest              
          Truck Stop since 1994.  Midwest Truck Stop has been profitable,             
          and the value of its stock has increased since petitioner bought            
          it in 1994.                                                                 
               In 1997, petitioner bought the Greenfield Trading Post, a              
          gas station and convenience store.  Petitioner has operated                 
          Greenfield Trading Post as a Schedule C business since 1997.                
               Petitioner maintains detailed accounting records for Midwest           
          Truck Stop and the Greenfield Trading Post.  Greenfield Trading             
          Post has daily computerized financial reports which petitioner              
          reviews twice a week.  Midwest Truck Stop has a manual ledger               
          system with quarterly and annual reports.  Midwest Truck Stop               
          also tracks large inventory items (such as fuel) daily.                     
               2.   Mrs. Davis                                                        
               Mrs. Davis began her career as a computer operator at                  
          Southern Colorado State University, where she worked from 1964 to           
          1970.  She has worked for Dillons Stores, a retail grocery chain,           
          since 1978.  She worked as a cashier from 1978 to 1979, as a head           
          cashier from 1979 to 1987, and as an office manager since 1987.             

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