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1998 Tax Year
For their 1998 taxable (calendar) year, the Spruills made a
joint return of income (the 1998 return), reporting, principally,
salary earned by petitioner and business income earned by Mr.
Spruill.
Petitioner’s salary derived from two employers. During the
first 2 months of 1998, she worked in the audit department of
West Quality Food Service (West), where she oversaw West’s
numerous bank accounts, assisted with inventories, cleared
checks, and handled other miscellaneous tasks. For a short
period during those 2 months, she supervised West’s accounts
payable department. During the remainder of 1998, she worked for
the City of Ellisville, Mississippi, in the water department,
where she performed billing services.
Mr. Spruill’s business income derived from his self-
employment as a contract oil well pumper. Mr. Spruill owned
neither a computer nor a typewriter, and petitioner assisted Mr.
Spruill in his business by hand-writing invoices. She prepared
the invoices on the basis of information received from Mr.
Spruill and, at the end of each month, she prepared a summary of
invoices that Mr. Spruill gave to his accountant. Petitioner did
not see the moneys collected against those invoices, nor did she
see any record of the bank deposits made by Mr. Spruill from
those collections. She was not a signatory with respect to Mr.
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