Leo and Alla Goldberg - Page 21

                                        -21-                                          
               During 1990 and 1991, petitioner purchased the following               
          cashier's checks with funds from California Federal account                 
          number 6130:                                                                
                    Date                Payee           Amount                        
                    12/31/90       Coastline Imports   $ 8,500                        
                    01/03/91       Coastline Imports   5,340                          
                    02/20/91       Ranko Balog Co.     3,600                          
                    07/17/91       Sharp Auto Sales    17,000                         
          These checks were used to pay expenses of the resale vehicle                
          business.                                                                   
               Petitioners did not pay any of the claimed $62,808 of                  
          expenses for the vehicle resale business with their own funds.              
          Vladimir Chorny                                                             
               During 1990, petitioners received the following amounts from           
          Vladimir Chorny (Chorny):                                                   
               Date            Amount             Purpose                             
               01/27/90       $ 5,000        Real estate services                     
               02/19/90       1,800          Real estate services                     
               02/26/90       60             [Unclear from the record.]               
               02/26/90       2,435          Real estate services                     
               04/07/90       1,050          Possibly real estate services            
               04/12/90       15,412         Engineering consulting                   
          Petitioners reported $5,285 of the above amounts on their 1990              
          Schedule C as income from real estate consulting.                           
               During 1991, petitioners received the following amounts from           
          Chorny:                                                                     
                         Date                Amount                                   
                         07/29/91            $  250                                   
                         09/02/91            9,000                                    





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