Eric A. and Jane C. Lanigan - Page 6

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                  $83,173.97 of the $83,262.91 income reported on the Forms                               
                  1099 attached to the return as filed with the IRS.  See                                 
                  supra n.3.  Again this $143,437.37 is exactly $88.94 less                               
                  than the total of the Forms 1099 and W-2 attached to the                                
                  return as filed with the IRS.                                                           
            Taxable Year 1991                                                                             
                  Forms W-2                   $39,548.06                                                  
                  Forms 1099                  12,875.24                                                   
                  Total Comp.                 $52,423.30                                                  
                                           Original Return                Revised Return                  
                  Wages                     1 $45,123.33                   $39,548.06                     
                  Interest                        149.57                         149.57                   
                  Business Income              (9,990.95)                     2,884.29                    
                  Self-Employment Tax                                        (203.77)                     
                  Total                      $35,281.95                    $42,378.15                     
                  Adj. Gross Inc.            $35,281.95                   2 $42,138.58                    
                  Sched. C                                                                                
                  Gross Receipts             $                            3 $12,875.24                    
                  Total Expenses               (9,990.95)                   (9,990.95)                    
                        Net Profit           $                             $ 2,884.29                     
                  1The record does not explain the source of this $45,123.33                              
                  figure that petitioner placed on the return.                                            
                  2There is no explanation as to why this figure is $239.57                               
                  less that the preceding figure.  In any event, with the five                            
                  personal and dependency exemptions claimed by petitioners                               
                  and with Schedule A itemized deductions of $38,918.12,                                  
                  petitioners' return reported no taxable income for 1991,                                
                  showing instead a negative figure of $7,529.                                            
                  3It appears that the IRS representative entered the                                     
                  $12,875.24 in gross receipts and computed the net profit at                             
                  $2,884.29.                                                                              
                  Attached to petitioners' 1990 return as filed were four                                 
            Forms 1099 and one Form W-2; attached to the 1991 return as filed                             
            were four Forms 1099 and three Forms W-2.  The revised figures                                
            used by the IRS representative were generally the figures shown                               




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