Anthony and Linda Walters - Page 8

                                        - 8 -                                         
          Item                          1987      1988      1989                      
               Ordinary income from                                                   
               business activity     $6,747    $7,280    $5,359                       
               Guaranteed payment      29,900    32,900    31,500                     
                 Total             36,647    40,180    36,859                         
               In 1990, petitioner was the target of a criminal                       
          investigation.  Petitioner was charged with three counts of                 
          willfully and knowingly attempting to evade Federal income tax by           
          filing false and fraudulent returns.  Count 1 pertained to                  
          taxable year 1987, while the second and third counts pertained to           
          taxable years 1988 and 1989, respectively.  Petitioner entered a            
          guilty plea to count 3.                                                     
               Petitioners concede that they underreported income in each             
          taxable year at issue.  Petitioners maintain, however, that the             
          amount of unreported income for each taxable year at issue is               
          equal to the amount of personal living expenses which petitioner            
          paid by drawing checks against Fruitland's checking account, plus           
          one-half of the cashier's checks purchased by petitioner during             
          the taxable year, less one-half of the amount of cashier's checks           
          negotiated during the taxable year, less the amount of income               
          reported as received from Fruitland on petitioners' tax return.             
          The following table illustrates petitioners' computation of                 
          unreported income for each taxable year at issue:                           









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