Robert D. Sparrow - Page 9

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          worth of appraised gems for 767,820 shares of NRG International             
          Stock at .30/share.”  Pursuant to this agreement, Mr. Sparrow and           
          Mr. Slaziz exchanged 767,820 shares of NRG for gems valued by               
          Mr. Slazis at $230,346.  Petitioners did not include this                   
          $230,346 in their 1987 gross income.                                        
               During 1987, Mr. Sparrow transferred to Leroy J. Isaac, Jr.            
          2,500 shares of Noble.                                                      
               During 1987, Michael Allred (Mr. Allred) sold NRG on behalf            
          of petitioners.  Mr. Sparrow received a $1,750 check from                   
          Mr. Allred, dated March 17, 1987, and payable to Mr. Sparrow.               
          Mr. Sparrow received a $200 check from Mr. Allred, dated                    
          March 27, 1987, and payable to Mr. Sparrow.  Mr. Sparrow received           
          a $2,500 check from Mr. Allred, dated April 6, 1987, and payable            
          to Mr. Sparrow.  Mr. Sparrow received a $1,500 check from                   
          Mr. Allred, dated April 22, 1987, and payable to Mr. Sparrow.               
          Petitioners did not include the $5,950 of aggregate proceeds from           
          Mr. Allred in their 1987 gross income.                                      
               Petitioners maintained control over Noble’s bank account               
          during 1987.  During 1987, Mr. Sparrow sold to Gordon LaMont                
          shares of Noble for $900.  Mr. Sparrow received a $900 check for            
          this sale.                                                                  
               Petitioners engaged the brokerage firm of Piper, Jaffray               
          & Hopwood, Inc. (Piper, Jaffray) to sell stock on their behalf              
          during 1987.  On January 6, 1987, Piper, Jaffray sold 1,300                 
          shares of Centurion Mines Corp. on behalf of petitioners for                




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