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J&R Checking Account
A business checking account, account 002-506610, in the name
of “J & R ‘A TRUST’” (the J&R checking account), was opened at
Santa Lucia National Bank no later than February 25, 1994. 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. The address shown on the J&R
checking account signature card, checks, and monthly statements
is the same as the address shown on petitioners’ tax returns.
All checks drawn on the J&R checking account during 1995 were
signed by either James or Rita Snyder. Such checks included
checks drawn to the order of Rita Snyder, James Snyder, Robert C.
Miller, D.D.S., Big Creek Lumber Co., Southern California Gas
Co., Pacific Bell, All States, Wal Mart, Home Furniture Gallery,
Dan’s Economy Tires, Albertsons, Paso Robles Waste Disposal, New
Covenant Church of God, K Mart, Steven J. Harmon, M.D., Central
Coast Pathology, Payless Shoes, Musician’s Emporium, Bakery
Works, and Bauer Speck Student Council.
Petitioners’ Residence
Petitioners purchased their personal residence (the
residence), located at 386 Quarterhorse Lane, Paso Robles,
California, on November 9, 1992. The grant deed by which they
acquired the residence (the first grant deed) shows the grantees
as “James D. Snyder and Rita K. Snyder, husband and wife as
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Last modified: May 25, 2011