Albert J. and Helen R. Desantis - Page 24

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               Distributions from particular line items in the construction           
          budgets were also made to petitioner before cost savings were               
          computed.  Such distributions were known internally as "owner's             
          check request(s)".  On August 31, 1983, for example, an owner's             
          check request was issued to petitioner from Newtowne in the                 
          amount of $20,496.58.  This amount is not reflected on                      
          petitioner's 1983 return.  Petitioner failed to attach to that              
          return a schedule indicating how he determined his gross receipts           
          for 1983.  Petitioner prepared a document entitled "1099 Income"            
          which purports to reflect amounts he received during 1983 for his           
          financial consulting services.  This document was not presented             
          to Meeks when he reviewed petitioner's return for that year.  The           
          owner's check request is not reflected on this document.                    
               Petitioner's 1984 return does not reflect the amounts he               
          received from Newtowne in cost savings.  As indicated, petitioner           
          attached a schedule to his 1984 return which itemized the income            
          he received from "Financial Consulting".  The schedule does not             
          state that he received payments from Newtowne.  Petitioner                  
          reported "other consulting fees" on the schedule in the amount of           
          $180,000.  It is unclear whether "other consulting fees"                    
          represents the amounts petitioner received from Newtowne for his            
          consulting services, cost savings, or a portion of the cost                 








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