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managed account investor and then transferred through GSC America
to GSC:
Years in Issue
Purpose 1984 1985 1987
Hedge transactions $114,025 $ 0 $ 0
Payments of principal 58,380 25,334 45,865
and interest on managed
account funds
Purchase of Krugerrands 0 0 37,725
$100,000 transfer 0 0 100,000
Total $172,405 $25,334 $183,590
Tax Returns
The following schedule reflects the date filed, timeliness,
gross income reported, and filing status relating to each of
petitioner’s Federal income tax returns for 1984 through 1987.
Gross Income
Return Date Filed Filed Reported Filing Status
1984 8/15/85 timely $147,000 married filing jointly
1985 6/13/86 untimely $174,900married filing jointly
1986 2/26/88 untimely$254,573 married filing separately
1987 4/7/89 untimely $83,600married filing separately
The above gross income reported on the tax returns for each
year consisted primarily of petitioner’s salary income from GSC
and Barbara B. Rehtorik’s salary income from her employment as
manager of a retail clothing store.
Petitioners did not include as income on their 1984 and 1985
joint Federal income tax returns, and petitioner did not include
as income on his 1987 individual Federal income tax return, any
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