Derwyn J. Booker - Page 8

               Petitioner received commissions from Encore in the amount of           
          $11,010 in 1984, and in the amount of $2,976 in 1985, with                  
          respect to his 1984 master lease sales.  Petitioner claimed                 
          deductions in the amount of $9,164 and an investment tax credit             
          in the amount of $17,808 with respect to his participation in the           
          Encore program during 1984.                                                 
               On September 12, 1986, the U.S. District Court for the                 
          Eastern District of California permanently enjoined Mr. Collings,           
          as shareholder and president of Encore, from taking any action in           
          furtherance of the organization, promotion, advertising,                    
          marketing, selling or offering for sale, any new or future                  
          interest in the Encore master recording lease programs.                     
          The Carter Company                                                          
               Petitioner entered into an investment agreement with the               
          Carter Co. (Carter) on January 4, 1983.  Carter held itself out             
          to potential investors as a company engaged in the medical                  
          factoring business, purchasing medical accounts receivable and              
          insurance claims from doctors at a discounted rate.  Petitioner             
          did advance funds to Carter under the investment agreement.                 
          Petitioner claims to have contributed a total of $76,050,                   
          however; the record is not clear as to the precise amount of                
          petitioner's investment.  No security or collateral was given for           
          petitioner’s advances to Carter.  Carter issued promissory notes            
          to petitioner in exchange for his contribution.  Carter made                
          quarterly payments to its investors at a rate of 7 to 10 percent            

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