Stanley P. Zurn - Page 4

           Date            Account No.          Amount                                
          Apr. 14        064 641-302538             $60,588                           
          Apr. 16        064 641-302538         57,000                                
              Apr. 17        131-403443-8           208,406                          
                    Total                    325,994                                  
          With respect to the $60,588 amount, respondent conceded before              
          trial that $60,000 was not to be included in income, leaving $588           
          in controversy.  Concerning the $57,000 item, respondent                    
          conceded, on brief, that the record reflected that it is not                
          includable in income for 1986.  The $208,406 item remains in                
               Lowell Thomas Nelson (Mr. Nelson) was involved in the                  
          business of buying and selling real estate investment property.             
          He met petitioner in the early 1980's in connection with                    
          petitioner's dealings in real property.  Mr. Nelson was given               
          power of attorney by petitioner with respect to a specific                  
          property transaction.  It was customary for Mr. Nelson to hold              
          money on behalf of petitioner.  Petitioner had established a bank           
          account of which he and Mr. Nelson were cotrustees, which enabled           
          Mr. Nelson to withdraw funds from the account.  The account was             
          opened at Mr. Nelson's request due to petitioner's informal                 
          manner of conducting business and because petitioner sent Mr.               
          Nelson relatively small sums of money for various purposes which            
          had accumulated and collectively became a substantial amount.               
               During the period 1982 through 1987, petitioner and Mr.                
          Nelson were involved in four or five transactions together.  On             

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Last modified: May 25, 2011