Julian O. Von Kalinowski and Penelope J. Von Kalinowski - Page 6

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          Petitioner and Mr. Von Kalinowski borrowed the funds for                    
          petitioner’s share of the startup costs.  In 1985, petitioner and           
          Mr. Von Kalinowski bought out petitioner’s co-owner in the travel           
          agency for approximately $25,000.                                           
               Windsor Travel was operational from 1984 to 1999.  Over this           
          time period, Mr. Von Kalinowski invested over $500,000 in the               
          business on behalf of petitioner, and such amounts were used to             
          fund the operations of the agency.  In 1999, petitioner sold the            
          assets of Windsor Travel for approximately $25,000 plus a sliding           
          percentage of revenue generated from the transferred accounts.              
          Financial Matters                                                           
               Petitioner and her husband maintained two bank accounts.               
          While each of these accounts was titled in the couple’s joint               
          names, the couple regarded one as petitioner’s checking account             
          and the other as Mr. Von Kalinowski’s checking account.                     
          Petitioner used the funds in her checking account to pay the                
          couple’s grocery bills and other personal expenses, and Mr. Von             
          Kalinowski made periodic deposits into this account for such                
          purposes.  The bank statements on petitioner’s checking account             
          were sent to the couple’s residence and received by petitioner.             
               The bank statements on Mr. Von Kalinowski’s checking account           
          were sent to his office and received by his secretary, Gina                 
          Hester.  Ms. Hester served as Mr. Von Kalinowski’s personal                 
          secretary from 1952 until just prior to his retirement in 1985,             

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