Robert D. Sparrow - Page 4

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          Individual Income Tax Return, on October 1988, using the status             
          of “Married filing joint return”.  They filed a 1987 Form 1040 on           
          April 15, 1988, using the status of “Married filing joint                   
          return”.  They filed a 1988 Form 1040, on October 17, 1990, using           
          the status of “Married filing joint return”.  They did not                  
          receive an extension of time to file any of these returns.                  
               During 1986, Mr. Sparrow owned at least 1.5 million shares             
          of NRG Intl., Inc. (NRG), and Mrs. Sparrow owned at least 150,000           
          shares of NRG.                                                              
               During 1986, petitioners sold to the husband of Dorothy S.             
          Hall, 10,000 shares of NRG for $2,000.  Mr. Sparrow received a              
          $2,000 check from Mrs. Hall, dated February 22, 1986, which was             
          payable to “Bob Sparrow”.  Petitioners did not include this                 
          $2,000 in their 1986 gross income.                                          
               On July 10, 1986, Mr. Sparrow sold to Norman C. Hall, 10,000           
          shares of NRG for $500.  Petitioners received a $500 check from             
          Mr. Hall, dated July 10, 1986, which was made payable to “Bob               
          Sparrow”.  The $500 was gain from the sale of stock.  Petitioners           
          did not include this $500 in their 1986 gross income.                       
               During 1986, Mr. Sparrow sold to Stanley L. Evans some                 
          shares of NRG for $11,800.  Mr. Sparrow received a $11,800 check            
          from Mr. Evans, dated July 21, 1986, which was payable to “Bob              
          Sparrow”.  Petitioners did not include this $11,800 in their 1986           
          gross income.                                                               






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