Stanley B. and Rose M. Whitten - Page 5

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               of any person or the mention of anything on the Program                
               without disclosure to NBC prior to broadcast is a                      
               federal offense punishable by fine and/or imprisonment.                
               I agree that if anyone tries to induce me to do any                    
               such act, I shall immediately notify a NBC Program                     
               Practices representative.                                              

          The release form further states that any travel undertaken by a             
          contestant in connection with the contestant's appearance on the            
          program shall be at the contestant's sole risk and expense.                 
          Petitioner, as well as his wife and three of his children,                  
          flew to Los Angeles on February 7, 1991, and petitioner appeared            
          for the taping of "Wheel of Fortune" as scheduled.  Petitioner              
          won three consecutive games and was awarded cash prizes in the              
          total amount of $14,850 and a 1991 Chevrolet Geo Tracker                    
          automobile.  The "Wheel of Fortune" programs that petitioner                
          appeared on were televised nationally on February 18, 19, and 20,           
          1991.                                                                       
          As indicated, petitioners filed a joint 1991 Federal income                 
          tax return (Form 1040).  Petitioner's winnings from the "Wheel of           
          Fortune" game show were reported as "other income" on line 22 of            
          Form 1040 in the amount of $19,830.  The $19,830 entry represents           
          the sum of the value of the GEO Tracker and petitioner's cash               
          winnings of $14,850, reduced by the expenses that petitioner and            
          his family purportedly incurred, namely $1,820, for                         
          transportation, meals, and lodging in order to participate as a             







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