David E. and Rebecca Newman - Page 4




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                  While petitioner sometimes went to Lee’s office to view the                          
            computer chips that Lee had purchased, petitioner never took                               
            possession of the chips, did not maintain any inventory or supply                          
            of computer chips, did not know the sales price of the computer                            
            chips, and did not maintain any records relating to the purchase                           
            or sale of the computer chips.  The only records petitioner                                
            maintained were of the amount of funds that he advanced to Lee                             
            and the amount of the return that Lee owed him on those advances.                          
                  During 1991, petitioner received a return on his advances                            
            and commissions from Lee in the amount of $799,550.  During 1992,                          
            petitioner received a return on his advances from Lee in the                               
            amount of $340,152.  As of December 31, 1991, Lee owed petitioner                          
            expected returns of $250,000 on funds that petitioner had                                  
            advanced to him.  Likewise, as of December 31, 1992, Lee owed                              
            petitioner expected returns of $140,000 on funds that petitioner                           
            had advanced to him.                                                                       
                  For the 1991 tax year, petitioners reported $799,550 as                              
            gross receipts and $250,000 as costs of goods sold on the                                  
            Schedule C attached to their tax return.  For the 1992 tax year,                           
            petitioners reported $340,152 as gross receipts and $140,000 as                            
            costs of goods sold on the Schedule C attached to their return.                            
            The gross receipts figures shown on petitioners’ 1991 and 1992                             
            Schedules C do not reflect the sales of the computer chips by Lee                          
            to third parties.  Rather, the gross receipts represent                                    






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