Albert J. and Helen R. Desantis - Page 32

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               AJD/Robin Woods, Ltd.                           $63,000                
               Rivergreen Buildings 1--10                      135,000                
               Brafferton Buildings 30 and 31                   20,000                
               Olde Sawmill on the Lake Buildings 1--8         128,100                
               Old Sawmill on the Lake II Buildings 1--9       134,700                
               Total                                         480,800                  

          7.  The Tax Returns                                                         
               Petitioners filed joint Federal income tax returns for the             
          taxable years 1982, 1983, and 1984.  Schedules C of these returns           
          reflect that petitioner, doing business as "Albert J. DeSantis",            
          engaged in "Financial Consulting".  On Schedule C of his 1982               
          return, petitioner reported $361,222 in gross receipts or sales.            
          On Schedule C of his 1983 return, petitioner reported $470,806 in           
          gross receipts or sales.  Petitioner did not indicate on the 1982           
          and 1983 returns what specific items of income represented the              
          gross receipts.  There is no explanation as to how petitioner               
          calculated gross receipts on Schedules C of his 1982 and 1983               
          returns.  On Schedule C of his 1984 return, petitioner reported             
          $2,742,409 in gross receipts or sales.  Petitioner attached a               
          schedule which itemized the income he received from "Financial              
          Consulting" in 1984.  There is an entry on the schedule for                 
          "other consulting fees" in the amount of $180,000.  As indicated,           
          petitioner did not provide an explanation of what fees he                   
          received and how he calculated this amount.                                 








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