Thomas A. Johnson - Page 5

          petitioner would get the two best seats available for any concert           
          or show that he wanted to attend.                                           
               Petitioner expected the advances to be returned, but this              
          did not happen with regularity.  To gain some control over the              
          payment process, petitioner made the necessary arrangements so              
          that customers could use a credit card to pay Finnimore for                 
          tickets.  Petitioner controlled the credit card receipts and also           
          set up a bank account in the name of Ticketline (Ticketline                 
          account) to hold those receipts.  This arrangement made the money           
          accessible to petitioner rather than having it go through                   
          Finnimore, who otherwise might have kept a fair amount of it.               
          Petitioner had sole signatory authority on the Ticketline                   
          account.  Credit card receipts were deposited directly to the               
          Ticketline account, and petitioner made periodic deposits into              
          that account of any money sent to him by Finnimore.  He regularly           
          advanced moneys from this account to Finnimore for the purchase             
          of tickets.                                                                 
               During 1988, petitioner had signatory authority over three             
          other accounts:  The Todge Trust account, the Universal Life                
          Church, Inc. (ULC) account, and an equity line of credit.                   
          Petitioner occasionally advanced moneys from these accounts for             
          the purchase of tickets by Finnimore.                                       
               Finnimore did not execute promissory notes for the funds he            
          received from petitioner.  Petitioner reported no interest income           
          for 1988 related to the funds advanced to Finnimore.                        

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