Walton A. Sutherland - Page 10

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               Buying                                                                 
               in             $0        $73,700   $40,300   $56,250                   
               Front money                                                            
               deposit        0         111,200      0         0                      
                    Total     $0        $184,900   $40,300   $56,250                  
               ------------------------------------------------------                 
                1989          Caesars   Tropworld    Trump   Ballys                   
               Buying                                                                 
               in             $59,900   $48,150   $14,400     $0                      
               Front money                                                            
               deposit        0          0           0        0                       
                    Total     $59,900  $48,150   $14,400     $0                       
          Petitioner's Tax Returns                                                    
               Petitioner reported the following items of gross income on             
          his Federal income tax returns for the years in issue:                      
                                   1987             1988           1989               
          Wages                    $65,917        $45,379        $48,922              
          Taxable interest income     105         147         238                     
          State tax refund              0              16        221                  
          Dividend income          0            0                33                   
               Total               $66,022        $45,542        $49,414              
               Petitioner made no disclosures in his 1987 Federal income              
          tax return or in a statement attached to that return of any                 
          amounts omitted from that return.                                           
          Unreported Income                                                           
               Petitioner failed to report an item of gross income in the             
          amount of $408,318 received in 1987.                                        
          Negligence                                                                  
               Petitioner and Hester acted together to structure receipt of           
          the $408,318 so that petitioner could retain control of it but              
          claim that he had not received it for tax purposes.                         






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