Jeanne M. Trent - Page 3




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          Expenses were separated into columns for rent, utilities, and               
          suppliers.  Personal expenses were logged by petitioner in the              
          ledger as a draw.  In 1994, Paradise hired a bookkeeper, Mary A.            
          Hogland, to prepare financial statements and to prepare the joint           
          Federal return of petitioner and S. Trent.                                  
               Petitioner and S. Trent timely filed a joint Federal income            
          tax return for 1994, claiming a refund of $896.  During 1994,               
          Paradise was the sole source of income for petitioner’s family.             
          Paradise’s income and expenses were reported on Schedule C,                 
          Profit or Loss From Business, to petitioner’s and S. Trent’s Form           
          1040.                                                                       
               In 1995, petitioner and S. Trent experienced marital                   
          difficulties.  In response to incidents on November 23 and                  
          November 25, 1995, petitioner filed a petition to order S. Trent            
          to appear for a hearing on domestic abuse with the Second                   
          Judicial District Court for Bernalillo County in New Mexico.                
          Petitioner also filed a Petition for Order Prohibiting Domestic             
          Violence on November 27, 1995.  On November 13, 1996, a divorce             
          decree was entered by the court.  In the divorce decree, S. Trent           
          received control of Paradise and retained all of the business-              
          related material and assets.  Pursuant to the divorce decree,               
          S. Trent assumed all business liabilities including any future              
          taxes or debts associated with Paradise.                                    








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