Robert D. Sparrow - Page 5

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               During 1986, Mr. Sparrow maintained a stock account at                 
          Anderson Bryant & Co. (Anderson Bryant).  Mr. Sparrow received a            
          $9,998 check from Anderson Bryant, dated August 1, 1986, which              
          was payable to “Robert D. Sparrow”.  Petitioners did not include            
          this $9,998 in their 1986 gross income.                                     
               During 1986, the brokerage firm of Wilson-Davis & Co.                  
          (Wilson-Davis), purchased and sold stock for petitioners.  On               
          August 12, 1986, Wilson-Davis sold 40,000 shares of NRG on behalf           
          of petitioners for $11,284, and purchased 1,300 shares of                   
          Centurion stock on behalf of Mr. Sparrow for $985.  The cost of             
          the purchase was deducted from the proceeds from the sale, and              
          Mr. Sparrow received a $10,299 check from Wilson-Davis, dated               
          August 19, 1986.  Petitioners did not include the $11,284 in                
          their 1986 gross income.                                                    
               On August 25, 1986, Wilson-Davis sold 40,000 shares of NRG             
          on behalf of Mr. Sparrow for $7,020.  On August 26, 1986,                   
          Mr. Sparrow purchased 1,000 shares of Centurion for $665, which             
          amount was deducted from the proceeds of the prior day’s sale.              
          Mr. Sparrow received a $6,354 check from Wilson-Davis dated                 
          August 29, 1986.  Petitioners did not include this $7,020 in                
          their 1986 gross income.                                                    
               On September 18, 1986, Wilson-Davis sold 10,000 shares of              
          National Division stock on behalf of Mr. Sparrow for $557.                  
          Mr. Sparrow received a $557 check from Wilson-Davis dated                   






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