Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 28

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          and deposits were made into that account through October of 1986.           
          No records from the autobody shop were ever provided to                     
          respondent's revenue agent.  Respondent's revenue agent computed            
          the autobody shop's profit as follows:  Total receipts of $83,544           
          consist of the deposits into its bank account of $71,544 and cash           
          expenditure for annual rent which was approximately $12,000.                
          From this total, Ms. Russell subtracted cost of goods sold of 40            
          percent.  Ms. Russell computed that the partnership had a net               
          profit of $35,726.  Michoff, Jr., retained a 25-percent interest            
          in the autobody shop through 1986.  Ms. Russell therefore                   
          determined that the net profit of Michoff, Jr., was $8,932, which           
          was 25 percent of the net profit from the partnership.  Neither             
          Michoff, Jr., nor Michael Juarez filed a partnership return for             
          the autobody shop for the 1986 tax year.                                    
               Michoff, Jr., made a $10,000 cash down payment on the                  
          purchase of property from Mr. and Mrs. Knight (the Knight                   
          property) in the 1986 tax year.  Michoff, Jr., contends that the            
          source of this payment was a loan from Dan Maggard.  However,               
          Michoff, Jr., failed to prove this contention.  Michoff, Jr.,               
          testified that these funds came from a loan, and he presented a             
          list of loans which he claims to have received from Dan Maggard.            
          This list was recently prepared by Michoff, Jr., in preparation             
          for this litigation.  Additionally, it is only signed by Dan                
          Maggard and not Michoff, Jr.  Mr. Maggard signed this document at           
          the request of Michoff, Jr.  At trial, Mr. Maggard testified that           

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