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proper income tax return and the Buyer agrees it will
issue a timely form 1099. Such amount shall be paid in
manner and form as follows:
a. Two Hundred Fifty-one Thousand One
Hundred Twenty Dollars and Forty-nine Cents
($251,120.49) thereof at the Closing hereinafter
described in manner and form as set forth in Schedule B
attached.
During 1976, petitioner received checks totaling $351,150.19 from
Bergman & Barth.
On or about March 1, 1976, petitioner began to practice law
under the name Leslie R. Barth, Associates, P.C. (the law firm).
Petitioner was the sole owner of the law firm, although the name
was changed on or about June 1, 1978, to Barth & Richheimer, P.C.
During each of the years in issue, petitioner provided clients
with legal advice on Federal income tax matters.
During the years in issue, petitioner conducted business
through a variety of corporations and other entities controlled
by him. The law firm and other entities controlled by petitioner
issued checks to petitioner, to Ms. Barth, and to other entities
or accounts controlled by petitioner in the following amounts:
Year Amount
1976 $207,924.71
1977 258,696.39
1978 181,358.00
1979 403,443.61
1980 331,964.57
Funds withdrawn by petitioner from the various accounts were used
for personal purposes during the years in issue.
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