Gary W. McDonough - Page 7

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          submitted on the grounds of doubt as to liability7 and effective            
          tax administration.  Petitioner’s revised Form 433-A reported no            
          future income potential and assets with a total current value of            
          $232,436, including the following:8                                         
               Assets                           Current Value                         
                    Cash                          $52,251                             
                    Stock                         25,404                              
                    Furniture                     960                                 
                    Vehicles                      64,821                              
                    Real property(one-half                                            
                    interest)1                    89,000                              
                    Total                         232,436                             
               1 The real property consisted of petitioner and his wife’s             
          house in Westminster, California and property they owned in                 
          Prescott, Arizona.                                                          
               The Form 433-A also reported the following monthly items of            
          income and expenses:                                                        
                    Total Income                       Amount                         
                    Wages                              $8,110                         
                    Total Living Expenses                                             
                    Food, clothing, and miscellaneous $2,335                          
                    Housing and utilities              2,742                          
                    Transportation                     705                            
                    Health care                        1,747                          
                    Taxes (income)                     1,225                          
                    Life insurance                     28                             


               7 The doubt as to liability issues were not argued on brief            
          and not considered here.                                                    
               8 Form 433-A states that each asset reported on the form               
          should be valued at its “Current value”, defined on the form as             
          “The amount you could sell the asset for today”.                            




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