Leon L. Sicard and Eleanor Sicard - Page 8

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          Enterprises.  White Enterprises often drew on the accrued fees or           
          was paid contemporaneously for the services it provided.                    
               Prior to 1987, petitioner drew on the management fees                  
          accrued to him only twice.  On March 3, 1984, and April 23, 1984,           
          respectively, petitioner caused the partnership to pay him                  
          accrued management fees in the amounts of $10,000 and $15,000.              
          Because the partnership paid petitioner $25,000 in 1984, he was             
          owed $190,000 in accrued management fees by the end of December             
          1986.                                                                       
               During 1987, the partnership paid petitioner the $190,000              
          outstanding balance of the management fees accrued pursuant to              
          the compensation arrangement.  That sum was paid by five checks.            
          The checks were deposited into petitioner’s business checking               
          account with Indian Head Bank and Trust Co.                                 
               During 1987 and 1988, believing that it was required, Mr.              
          Davis and his assistant issued Forms 1099 to any noncorporate               
          recipient of payments from the partnership in 1987 of at least              
          $10 in interest or at least $600 for services.  During 1987, the            
          partnership issued to petitioner two Forms 1099 for 1986:  A Form           
          1099 in the amount of $460 for automobile-related fringe                    
          benefits, and a Form 1099 in the amount of $12,000 for equipment            
          rental fees paid to petitioner.  During 1988, the partnership               
          issued to petitioner Forms 1099 for the years 1984 and 1985 on              
          1987 Forms 1099 with the year changed to 1984 or 1985, as                   
          appropriate.  The Form 1099 for 1984 in the amount of $42,201.79,           




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