Adrian D. Troutman, Jr. - Page 4

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               Ms. Novak-O’Farrell made purchases for T-Foil Enterprises in           
          one of two ways.  Sometimes she purchased items with an American            
          Express card.  The American Express card had her name on it, but            
          the charges incurred on that card were billed to petitioner.  On            
          other occasions, Ms. Novak-O’Farrell purchased business items               
          with her own funds or her own credit card.  When she purchased              
          business items with her own funds or credit card, petitioner                
          would reimburse her, or she would write a T-Foil Enterprises                
          check to herself.  Petitioner periodically reviewed the American            
          Express bills and canceled checks.  There is no evidence that               
          petitioner objected to these practices during 1999.                         
               During 1999, Ms. Novak-O’Farrell and petitioner were friends           
          in addition to their employer-employee relationship.                        
               From October 1998 to March 2001, Ms. Novak-O’Farrell rented            
          a house from petitioner.  The parties did not execute a written             
          lease.  Ms. Novak-O’Farrell agreed to pay between $900 and $950             
          per month in rent, which petitioner raised to $1,200 sometime in            
          1999.  In or about July 1999, Ms. Novak-O’Farrell injured herself           
          and did not work.  From August 1999 through December 1999,                  
          petitioner and Ms. Novak-O’Farrell orally agreed that she would             
          pay only half the rent due (approximately $450 to $475).                    
          Petitioner’s Logging Road                                                   
               During 1999, Sherwood Trucking & Bulldozing installed a                
          logging road onto wooded land owned by petitioner.                          






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