Kamil F. and Nagwa Gowni - Page 11

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          owned and operated Ava Anthony.  Ava Anthony operated as a                  
          C corporation during the years in issue.  In 1996, Ava Anthony              
          owned land.  In 1998, Ava Anthony purchased 10 gasoline stations            
          from Presto Food Stores for approximately $9 million and operated           
          them through 1999.                                                          
          Bradshaw’s Employment by Petitioners                                        
               Beginning in May 1998, petitioners employed Bradshaw to do             
          the accounting for Mina of Sanford, Mina of Forest City, and                
          Shenody.  This arrangement eventually expanded to include Ava               
          Anthony and Bishoy.  Bradshaw did not do the accounting for                 
          petitioners’ other business entities and had not done any other             
          work for petitioners prior to May 1998.                                     
               From the time that he began working for petitioners,                   
          Bradshaw was aware that petitioners withdrew cash from the                  
          corporate bank accounts of Ava Anthony, Mina of Sanford, Mina of            
          Forest City, Bishoy, and Shenody before he could reconcile those            
          accounts.  Bradshaw was also aware that petitioners frequently              
          wrote checks from the corporate bank accounts of their business             
          entities and deposited them into their personal bank accounts.              
          Bradshaw advised petitioners to discontinue this latter practice.           
          The Mansours’ Income Tax Returns for 1996 through 1999                      
               On their joint income tax return for 1996, the Mansours                
          reported the following sources of income:                                   








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