Thomas A. Johnson - Page 4

          (1988).  It applies to issues of fact, issues of law, and mixed             
          issues of fact and law.  Id. at 283.                                        
               The taxable year 1987 was at issue in Johnson I, and that              
          opinion was based in part on petitioner's failure to meet his               
          burden of proof.  We have concluded that the issues now before              
          the Court were not necessarily litigated in Johnson I.                      
          Petitioner, in this proceeding, could prove different facts or              
          changed circumstances sufficient to distinguish this case from              
          Johnson I and to carry his burden of proof for the years at                 
               Petitioner resided in Vernon, Connecticut, at the time he              
          filed the petition.  He has a bachelor's degree in mathematics              
          and a master's degree in psychology.  Petitioner received                   
          training as an actuary and has consulted as a stock analyst.                
          Petitioner did not receive salary or wages in 1988.  Petitioner             
          has prepared his own income tax returns since 1981, and he                  
          reported his income and deductions for the taxable years 1988 and           
          1989 on the cash receipts and disbursements method of accounting.           
               In 1985, petitioner began purchasing concert tickets from              
          Robert Finnimore (Finnimore) through a business known as                    
          Ticketline.  Finnimore purchased tickets to concerts, plays, and            
          other events and then resold the tickets at a premium.                      
               Finnimore needed cash to purchase tickets, so petitioner               
          agreed to advance money to Finnimore, with the understanding that           

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