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During 1993, 1994, and 1995, petitioners paid rental expenses
with respect to the Toledo rental property totaling $6,668,
$6,330, and $10,239, respectively.
The only records that petitioners maintained with respect to
Mr. Owens’ painting business and the Toledo rental property were
their bank statements and the checks written on the joint bank
accounts that they maintained (the National City joint account
until May 18, 1993, and thereafter the Peoples joint account).
Petitioners prepared from those bank statements and checks a
monthly listing of the checks (petitioners’ monthly listing) that
they wrote. Petitioners’ monthly listings, when totaled for the
months during each of the years at issue,4 showed that petition-
ers wrote checks for labor costs on the joint bank accounts that
they maintained (the National City joint account until May 18,
1993, and thereafter the Peoples joint account) that totaled
$18,784.75 for 1993, $43,038.38 for 1994, and $74,545 for 1995.
During 1995, petitioners purchased property located on
Miller Street in Indianapolis (Miller Street property) for which
they paid at least $1,222. In addition, during that year,
petitioners made downpayments totaling $10,090 toward the pur-
chase of property located on Massachusetts Street (Massachusetts
4Petitioners’ monthly listings for 1993 that are in the
record do not include petitioners’ monthly listing for May 1993.
Instead, petitioners’ monthly listings for 1993 that are part of
the record include petitioners’ monthly listing for May 1996.
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