Daniel R. Leavell and Eva Lovene Leavell - Page 15

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                 On November 4, 1986, Eva, for a total stated consideration                               
            of $1,828,000, sold back to Christa Oil the above partial                                     
            interests in the three oil leases that she had received in                                    
            November of 1985.  Of the total stated consideration, $100,000                                
            was to be paid to Eva in cash, and the $1,728,000 balance due                                 
            under the contract with Christa Oil was to be reflected by the                                
            assignment to Eva of a specified number of barrels of oil to be                               
            produced from wells owned by Christa Oil, and by Christa Oil's                                
            commitment to make cash payments to Eva to the extent the barrels                             
            of oil Eva actually received under this contract and the $100,000                             
            downpayment were not adequate to fully pay Eva the total                                      
            $1,828,000 due under this contract.                                                           
                 On audit and based on records of Christa Oil, respondent                                 
            determined that Eva received under the above 1985 and 1986                                    
            transactions with Christa Oil, $66,913 in 1985, $165,923 in 1986,                             
            and $518,278 in 1987, in additional payments from Christa Oil.                                
            Respondent treated these payments as additional capital gain                                  
            income to petitioners for each respective year.                                               
                 During the audit, petitioners provided respondent's                                      
            representatives no information regarding the amount Eva received                              
            on the above transactions.  Petitioners have not established that                             
            these payments were reported anywhere on their joint Federal                                  
            income tax returns.                                                                           








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