James D. and Rita K. Snyder - Page 8




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          For each trust year in question, such income distribution                   
          deduction, along with a charitable contribution deduction of $860           
          for 1994, was sufficient to reduce reported taxable income to               
          zero.  A tax liability of zero was reported for each trust year,            
          1992 through 1995.                                                          
          Rita Snyder’s Business                                                      
               During the years in issue, Rita Snyder engaged in business             
          as a paid tax return preparer, under the name “Complete                     
          Connections”.                                                               
          Complete Connections Checking Account                                       
               A business checking account, account number 002-502704, in             
          the name of “Complete Connections” (the Complete Connections                
          checking account), was opened at Santa Lucia National Bank no               
          later than August 9, 1990, and was closed on January 28, 1999.              
          The signature card for that account describes the account as a              
          trust account and shows as signatories both Rita and James                  
          Snyder, each of whom is described as a manager.  All checks drawn           
          on the Complete Connections checking account during 1995 were               
          signed by either James or Rita Snyder.                                      
          Federal Income Tax Return for J&R Trust                                     
               Beginning with 1992, and continuing for 1993, 1994, and                
          1995, either Rita or James Snyder made a return of income on                
          Form 1041, U.S. Fiduciary Return of Income (for 1992 and 1993) or           
          U.S. Income Tax Return for Estates and Trust (for 1994 and 1995),           






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