Tommy Owens, Jr. and Dawn R. Owens - Page 5




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               Petitioners were the only individuals who lived in the                 
          various residences that they occupied during the years at issue.            
          During those years, they did most of their grocery shopping at              
          Sam’s Club.                                                                 
               During the years at issue, petitioners did not inherit any             
          money or property, nor did they apply for, or receive, any bank             
          loans.                                                                      
               Petitioners maintained a joint bank account, account No.               
          8011127, at National City Bank (National City joint account)                
          until May 18, 1993, when they closed that account.  As of Decem-            
          ber 31, 1992, the balance in petitioners’ National City joint               
          account was $5.51.  On February 10, 1993, petitioners opened a              
          joint bank account, account No. 91138256, at Peoples Bank (Peo-             
          ples joint account) and made an opening deposit into that account           
          of $2,000.  As of December 31, 1993, the balance in petitioners’            
          Peoples joint account was $8,873.21.                                        
               In 1988, Mr. Owens started a painting business (painting               
          business) which he continued to own and operate during the years            
          at issue and which was petitioners’ primary source of income                
          during those years.  Ms. Owens assisted Mr. Owens in his painting           
          business and was paid nonwage compensation of $1,700 during 1993            
          and $1,900 during 1995.                                                     
               Mr. Owens’ painting business undertook primarily industrial            
          and commercial painting jobs.  In those jobs, Mr. Owens served              






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