Timothy C. Sadlier - Page 4

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                    Sources of Funds                  Tax Year:  1989                 
                    Interest income per return               $145                     
                    Rental income per return           7,800                          
                    Rental income increase (herein)           600                     
                    Gambling winnings per return       23,298                         
                    Sch. C Reentries gross receipts                                   
                    per return                              3,260                     
                    Sch. C Reentries gr. receipts                                     
               increase (herein)                            3,003                     
                    Reimbursement from New Horizons        11,700                     
                    NCNB acct #4319742 1/1/89 balance       9,998                     
                    Horse sale proceeds per return          2,500                     
                    Loan from mother                        6,000                     
                    Credit card cash advances              2,597                      
                    Total                              $70,901                        
                    (i) During 1989, petitioner had the following                     
               application of funds totaling $156,425:                                
                    Application of Funds               Tax Year:  1989                
                    Withholding credits per return         $3,302                     
                    Sch. C Reentries purchases                                        
               per return                                   6,231                     
                    Sch. C Reentries purchases                                        
               decrease herein                              (271)                     
                    Sch. C Reentries expenses                                         
                    per return                              5,462                     
                    Sch. E expenses per return              4,200                     
                    Sch. E depreciation per return     (1,677)                        
                    Loan to New Horizons               95,991                         
                    Personal expenses                  38,180                         
                    NCNB acct #4319742 1/1/89 balance      5,007                      
                    Total                              $156,425                       
                    (j) For the year 1989, petitioner had unexplained                 
               applications of funds in excess of sources of funds in                 
               the amount of $85,524, which petitioner failed to                      
               report on his fraudulent delinquent income tax return                  
               filed for the taxable year 1989, all with the intent to                
               evade tax for the period.                                              
                    (k) For 1989, petitioner failed to report bartered                
               rental income in the amount of $600, all with the                      
               intent to evade tax for the period.                                    





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