Paul A. and Marilyn J. Grothues - Page 4




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          corporations’ employees and wrote checks for the corporations’              
          combined employment tax liabilities.  In exchange for these                 
          services, petitioners’ corporations paid SWAS a handling fee.               
          Petitioners’ Federal income tax returns have never included a               
          Schedule C, Profit or Loss From Business, for a sole                        
          proprietorship known as SWAS or a partnership return on Form                
          1065, U.S. Partnership Return of Income, for a partnership known            
          as SWAS.                                                                    
               Mr. Kanz began working for petitioners and their                       
          corporations in 1981.  At that time, Mr. Kanz had known                     
          petitioners for approximately 10 years.  Mr. Kanz, then a                   
          licensed public accountant, performed services as an independent            
          contractor for petitioners’ corporations.  His responsibilities             
          included preparation of payroll tax returns and financial                   
          statements, the reconciliation of bank statements, and management           
          of petitioners’ corporations’ financial affairs.  He performed              
          these services for petitioners’ corporations and SWAS from 1981             
          to July 1990.  He billed each corporation for professional fees             
          based on his number of hours of service for that corporation.               
               Initially, SWAS maintained a payroll checking account at               
          Brooks Field National Bank in San Antonio, Texas.  In March 1987,           
          SWAS opened another account at Trinity National Bank in San                 
          Antonio, Texas.  Petitioners and Mr. Kanz were the only persons             








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