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primarily as a subcontractor who performed painting work for
various general contractors, although occasionally he performed
work directly for various owners of small businesses.
Petitioners, who did not maintain a separate bank account
for Mr. Owens’ painting business, generally deposited receipts
from Mr. Owens’ painting business into the National City joint
account that they maintained until May 18, 1993, and thereafter
into the Peoples joint account that they maintained.
Mr. Owens conducted his painting business both inside and
outside his home State of Indiana. He conducted that business
outside of Indiana in Ohio, Michigan, Kentucky, and Illinois.
While performing painting jobs outside the State of Indiana, Mr.
Owens received a lot of cash payments for his work. That was
because it would have been virtually impossible for him to have
cashed any checks received while conducting his painting business
outside the State of Indiana.
During 1993, 1994, and 1995, petitioners owned an Astro van,
a “box” truck (truck), and a Ford van. During 1995, petitioners
also purchased a minivan. Mr. Owens used at least in part one or
more of the vehicles that petitioners owned in conducting his
painting business. Petitioners did not keep a contemporaneous
log of their business mileage. Nor did petitioners determine as
of the beginning and the end of each of the years at issue the
odometer readings for any of the vehicles that they owned.
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