Francis M. Gagliardi - Page 4




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         knew that he had to substantiate his claimed deductions related              
         to American Redball with receipts, and he provided his business              
         receipts to his tax return preparer.                                         
              Eugene Hunner (Mr. Hunner) prepared Mr. Gagliardi’s tax                 
         returns when Mr. Gagliardi owned American Redball.  Mr. Hunner               
         has a B.A. in accounting and is a certified public accountant.               
         He worked 5 years at a national accounting firm, is two courses              
         shy of his master’s in tax at the University of Southern                     
         California, and has prepared tax returns for over 30 years.                  
         Ninety percent of Mr. Hunner’s professional work is preparing tax            
         returns.  Mr. Hunner prepares between 120 and 160 returns per                
         year.                                                                        
         1991:  Mr. Gagliardi Wins the Lottery                                        
              In 1991, Mr. Gagliardi won approximately $26,660,000 from               
         the California lottery (lottery proceeds).  Mr. Gagliardi elected            
         to receive payment of the lottery proceeds in 20 annual payments             
         of approximately $1,333,000 each (original annual lottery                    
         payment).                                                                    
              At the time he won the lottery proceeds, Mr. Gagliardi was              
         29 years old, was married, and had two children.  Since winning              
         the lottery proceeds, Mr. Gagliardi has not been employed.  After            
         winning the lottery proceeds, and before 1996, Mr. Gagliardi                 
         purchased a new home and custom-built motorcycles and regularly              
         went on vacations.  With the exception of the above expenditures             







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