Eric Wynn - Page 5

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          checking account made payable to Joe Bass in the amount of                  
          $31,115.  Neither of those adjustments is at issue in this case.            
               Four sets of transactions remain in issue:  (A) Funds paid             
          into a bank account in the name of "Ron Gelfman" in 1983; (B)               
          Renaissance's purchase of jewelry items from Faleck & Margolies,            
          Inc., in 1983 and 1984; (C) Renaissance checks made payable to              
          Weinstock & Yeager in 1983 and 1984; and (D) payments by a                  
          brokerage house, at petitioner's request, into a bank account in            
          the name of "Joe Bass" in 1984.                                             
          A.   Ron Gelfman                                                            
               On September 29, 1983, a person not identified in the record           
          opened a checking account at the Union City branch of the Trust             
          Company of New Jersey (the Trust Co.), in the name of Ron Gelfman           
          (Gelfman account).1  On October 31, 1983, a Renaissance check in            
          the amount of $68,200 was deposited in the Gelfman account.  The            
          parties have stipulated that Renaissance's corporate records                
          contain what purports to be a receipt from Ron Gelfman                      
          Associates, dated October 28, 1985,2 reflecting the sale of 14K             
          "gold findings" to Renaissance in the amount of $68,200.                    



          1  The record is replete with references to the names Ron or                
          Ronnie Gelfman, Gelman, and Geleman.  These are all different               
          spellings of the same name, and for simplicity we will use                  
          Gelfman to represent all three spellings.                                   
          2  Neither party addressed the fact that the receipt was                    
          dated 2 years after the check.  This apparent discrepancy does              
          not affect our decision.                                                    




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