Debra L. Streck and Donald W. Streck - Page 18

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          in bankruptcy in October 1983.15  Their 1986 financial statement            
          indicates that petitioners owned valuable furs and jewelry.                 
               These expenditures appear inconsistent with the amounts                
          petitioners reported on their tax returns and would have alerted            
          Mrs. Streck to the fact that there were understatements of income           



               15In his October debtor's petition filed in the U.S.                   
          Bankruptcy Court, Mr. Streck listed debts of $1,999,678 and                 
          assets of $548,994.  A financial statement prepared by                      
          petitioners' accountant, a C.P.A., based on information received            
          from petitioners, reflects petitioners' assets and liabilities as           
          of Sept. 30, 1986, as follows:                                              

          Assets                                                                      
          Cash and cash equivalents             $36,600                               
          Investments, nonmarketable          1,408,000                               
          equity securities                                                           
          Residence                             770,000                               
          Automobile                             54,500                               
          Furs, jewelry, household items,       200,000                               
          etc.                                                                        
          $2,469,100                                                                  
          Liabilities and Net Worth                                                   
          Income taxes, current year           $500,000                               
          balance                                                                     
          Notes payable, financial              817,800                               
          institutions                                                                
          Estimated income taxes, on            215,000                               
          the difference between the                                                  
          estimated current values of                                                 
          assets and the estimated                                                    
          current amounts of liabilities                                              
          and their tax bases                                                         
          Net worth                               936,300                             
          $2,469,100                                                                  





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