Stewart L. and Patricia A. Welch - Page 4




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          other items of reported gross income during those three years               
          were net rental income of $153 and $9 in 1993 and 1995,                     
          respectively, and gambling winnings of $5,000 in 1994.                      
               Petitioners purchased a home in 1987 for $109,200 and lived            
          there during the relevant time.  The home’s monthly mortgage                
          payments were $826.11 in 1993, $804.73 in 1994, and $993.12 in              
          1995.  Petitioners also owned a rental property.  The rental                
          property’s monthly mortgage payment is not disclosed in the                 
          record.  Interest payments on the rental property’s mortgage                
          totaled $4,346 in 1993, $4,067 in 1994, and $3,753 in 1995.                 
               Petitioners were sometimes assisted in the business by their           
          two sons, who worked for the business without pay.  One son,                
          Robert Ruth (Mr. Ruth), was born in 1972 and lived with                     
          petitioners through the first part of 1995 paying little of the             
          household’s expenses.  Mr. Ruth earned little income in 1993 and            
          1994 and earned $15,300 in 1995.                                            
               Petitioners purchased a 1990 Mustang for Mr. Ruth in 1992.             
          The Mustang’s monthly payment was $235.86, and the related                  
          monthly insurance payment was approximately $150.  Petitioners              
          also owned and made payments on four other vehicles; to wit, a              
          1992 Ford Bronco, a 1994 Ford Econoline Van, a 1995 Ford Bronco,            
          and a 1988 Chevy Van.  The respective monthly payments on these             
          vehicles were $235.86, $449.13, $409.07, and $483.83.                       








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