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FINDINGS OF FACT
The parties have stipulated some of the facts, which we
incorporate herein by this reference.
Petitioners
When they filed their petition, petitioners were married and
resided in New Bern, North Carolina. Petitioners filed joint
Federal income tax returns for all of the subject years.
Petitioners’ Businesses
During the years at issue, petitioners operated two
businesses: A grocery store known as Shop E-Z Mart and an
automobile dealership known as Moore’s Auto Sales (Moore’s Auto).
Petitioner Aljournia Moore (Aljournia) primarily operated Shop E-
Z Mart, and petitioner Lesely Moore (Lesely) primarily operated
Moore’s Auto.
Petitioners maintained a bank account for Shop E-Z Mart
(Shop E-Z Mart account) and a bank account for Moore’s Auto
(Moore’s Auto account) at Wachovia Bank. During the subject
years, petitioners deposited into the respective accounts
maintained for those businesses all income that they received
from Shop E-Z Mart and Moore’s Auto. The deposits into those
accounts were as follows:
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Last modified: May 25, 2011