Charles L. Fields and Barbara S. Fields - Page 19

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               Petitioners never reported any of CAI's funds used by them             
          as income on a personal tax return.  The total amount of CAI                
          funds in the A, C, and set-off accounts used for petitioners'               
          benefit totaled $705,107.17  Of this amount, $245,008 was used in           
          1980, $312,269 was used in 1981, and $147,830 was used in 1982.             
          Petitioner was aware that he could be charged with income from              
          CAI and the resulting tax liability.                                        
          6.  Reporting Requirements                                                  
               Petitioners' 1980 through 1982 tax returns were prepared by            
          their accountant, Seymour Schiller (Mr. Schiller).  In connection           
          with the preparation of those returns, petitioner did not tell              
          Mr. Schiller that petitioners had an interest in a foreign                  
          account during the relevant years.  Petitioners indicated on                
          their 1980 and 1981 tax returns that they did not have such an              
          interest during 1980 and 1981.  Petitioners did not report on               
          their 1982 tax return that they had an interest in a foreign                
          account during 1982.  Petitioners had an interest in CAI's bank             
          account during each of the subject years.                                   
          7.  Mrs. Fields                                                             
               Mrs. Fields is an educated woman, and she has been involved            
          in the business world in a limited capacity.  She received a                



               17 Respondent seeks to include only $669,124 of this income            
          in petitioners' gross income.                                               






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