Robert P. Petrocine - Page 3

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          upon commencement of his employment, petitioner received $103,000           
          as a loan from Dean Witter.  As reflected in a promissory note              
          signed by petitioner, beginning in 1989 this loan was to be                 
          repaid by petitioner in three annual installments of                        
          approximately $34,333 each, plus 10-percent annual interest, for            
          a total annual payment due of $37,767.                                      
               Under the terms of the loan agreement, as long as petitioner           
          worked for Dean Witter during 1989 through 1991, petitioner would           
          receive a yearend bonus in the amount of $37,767, which                     
          petitioner was required to return to Dean Witter, via a personal            
          check, in order to cover the annual $37,767 payment due on the              
          $103,000 loan from Dean Witter.  Of the $37,767 annual payment              
          due, $3,433 reflected interest due on the loan.                             
               On his 1988 Federal income tax return, petitioner did not              
          report the $103,000 loan proceeds received as income.  For 1988,            
          Dean Witter also apparently treated the $103,000 as a loan to               
          petitioner.                                                                 
               For 1989 and 1990, the record does not indicate how                    
          petitioner and Dean Witter treated the $37,767 yearend bonuses              
          received by petitioner.  For 1991, Dean Witter included the                 
          $37,767 yearend bonus paid to petitioner in the "wages" portion             
          of the Form W-2 that it issued to petitioner for 1991.                      
               On August 2, 1991, petitioner filed for bankruptcy.                    
          Petitioner's bankruptcy proceedings were closed on December 23,             
          1991.                                                                       




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