Robert L. Beck - Page 9

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               During the years in issue, Mrs. Beck occasionally worked in            
          Dr. Beck’s dental office and participated in recruiting employees           
          for his dental practice (the dental practice).  A few times each            
          week, Mrs. Beck called the dental practice to ask the practice              
          administrator how much money the office received for the day.               
               Mrs. Beck was a signatory on the dental practice’s bank                
          account at Nation’s Bank (the dental practice account).  From               
          December 1993 to January 1995, petitioners maintained a joint               
          personal account at Frost National Bank (the joint account).  In            
          addition, from November 1994 through January 1996, Mrs. Beck was            
          the sole signatory to an account at Frost National Bank (the                
          separate account).                                                          
               Dr. Beck employed a practice administrator who handled his             
          dental office affairs.  The practice administrator would fill out           
          checks to pay substantially all of the dental practice expenses.            
          Either Dr. Beck or Mrs. Beck would sign the checks.                         
               Dr. Beck accepted payment for his dental work in cash as               
          well as checks.  The dental practice offered its services at a              
          discount if the patient paid cash.  The dental practice employees           
          turned over to Dr. Beck all cash payments received.                         
               During 1993 and 1994, the dental practice would receive                
          from its patients, on average, $3,000 a day in cash.  From 1991             
          through 1994, only one cash deposit, in the amount of $2,000, was           
          made to the dental practice account.                                        

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