Don H. Wisden - Page 5

                                        - 5 -                                         
          Nonemployee Compensation     $8,677      $6,792        -0--0-                       
          Wages                    -0-       5,729     $ 5,963      $9,328            
          BLS Statistics           8,137     4,605      11,606   8,768                
          The sources of the nonemployee compensation and wages are not               
          identified in the notice of deficiency.                                     
               In 1989 and 1990, petitioner was single and living in a                
          house owned by his sister-in-law in Tucson, Arizona.  He                    
          contributed undisclosed amounts to the support and maintenance of           
          the house.  During these years he worked for Tucson Newspapers,             
          Inc., as a newspaper delivery person.  He also worked for                   
          Delivery Services, Inc., delivering packages to various locations           
          around Tucson.  Petitioner earned income from both of these                 
          companies but does not remember the amounts.                                
               In late 1990, petitioner moved from Tucson to St. George,              
          Utah.  In 1991, while living in St. George, petitioner held                 
          several jobs.  He was employed by Everex as an automated routing            
          machine operator for 3 months.  He worked for 3 months as a hotel           
          desk clerk for the Heritage Inn Motel (Heritage) in St. George.             
          He also worked as a desk clerk and a night auditor for the                  
          Peppermill Hotel Resort and Casino (Peppermill) in Mesquite,                
          Nevada, for a period of 3 months.  In each of these jobs                    
          petitioner worked 40 hours per week.  He was paid $5.50 per hour            
          at the Peppermill, $4.75 per hour at Everex, and $4.50 per hour             
          at the Heritage.  Some of these jobs might have started in 1990             
          and a portion of the income might have been earned in that year.            
          However, there is insufficient evidence in the record to support            






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