Joseph M. and Sybil G. Kawal - Page 5

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            family in the form of checks or cash, paying grocery bills for                                
            which Mr. Mahabir and/or his family were, or agreed to be,                                    
            responsible, and paying other people to whom Mr. Mahabir owed                                 
            money.  Sometime after 1990, when petitioner opened the checking                              
            account, he began depositing the JMS checks into that account,                                
            instead of cashing them at Linden Lumber.  However, in all other                              
            respects, Mr. Mahabir's arrangement with petitioner continued                                 
            through 1992.                                                                                 
                  When petitioner obtained a Social Security number (Social                               
            Security number) in either 1991 or 1992, he asked Mr. Mahabir to                              
            use it, but Mr. Mahabir would not do so.  Around 1992 or 1993,                                
            petitioner, who was concerned that he was depositing Mr.                                      
            Mahabir's money into petitioners' checking account and using it                               
            on behalf of Mr. Mahabir, his family, and/or certain of Mr.                                   
            Mahabir's acquaintances and who believed that Mr. Mahabir would                               
            fire him if he refused to continue complying with Mr. Mahabir's                               
            arrangement, raised his concerns with Mr. Mahabir and informed                                
            him that he wanted to discontinue Mr. Mahabir's arrangement.  At                              
            that point, Mr. Mahabir fired him.                                                            
                  JMS prepared a Form 1099-MISC (Form 1099) that showed that                              
            Joseph Kawal received $49,200 in nonemployee compensation from                                
            JMS during 1992.  The Social Security number shown on the Form                                
            1099 is not the Social Security number of petitioner.                                         








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