Patricia A. Hendricks and John J. Hendricks - Page 3

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          Hendricks did not discuss business matters with petitioner, nor             
          was petitioner ever an employee of any of Mr. Hendricks’s                   
               Mr. Hendricks maintained several separate business bank                
          accounts to which petitioner had no access.  The Hendrickses                
          maintained only one joint checking account from which petitioner            
          paid personal and household expenses.                                       
               Petitioner completed 2 years of college, where she studied             
          art.  Petitioner did not take any business courses or classes on            
          income taxation or preparation of income tax returns.  After                
          marrying Mr. Hendricks, petitioner stayed at home to raise their            
          five children and run their household.  Petitioner’s only                   
          involvement in family finances was to pay the monthly household             
          expenses.  Petitioner relied upon Mr. Hendricks for financial,              
          business, and tax decisions.                                                
               The Hendrickses have led frugal lifestyles.  There is no               
          evidence that during the relevant years they made any lavish or             
          unusual expenditures.                                                       
               On November 18, 1980, Mr. Hendricks met with the                       
          Hendrickses’ certified public accountant, Kurt Grosser (Mr.                 
          Grosser), and a broker for a partnership called Boulder Oil and             
          Gas Associates, 1980 (Boulder Oil and Gas).  Despite its being              
          the first he had heard of the partnership, during the meeting Mr.           
          Hendricks agreed to invest $94,002 in Boulder Oil and Gas and               

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Last modified: May 25, 2011