Melrel L. Stephens - Page 3

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          of documents that included her receipts for gambling, mortgage              
          interest, and other expenses.  Petitioner did not discuss with              
          the Preparer each document in the bag, and she did not review her           
          return with the Preparer after he prepared it.                              
               On January 28, 1989, petitioner won $7.2 million in the                
          California State Lottery, payable in yearly installments.                   
          Petitioner received a $361,000 installment of those winnings in             
          1993.  These winnings were reported on petitioner's 1993 tax                
          return.  No other income was reported thereon.                              
               During 1993, petitioner had an ownership interest in four              
          real properties located in California at the following addresses:           
          331 West 46th Street, Los Angeles; 22150 Salter Road, Perris;               
          8431 Hooper Avenue, Los Angeles; and 2232 Mortimer, Huntington              
          Park.  Petitioner also had an ownership interest in land in                 
          Chicot County, Arkansas.  None of these properties generated any            
          income in 1993.                                                             
               In 1993, petitioner paid the following mortgage interest and           
          real property taxes on the above-mentioned properties:                      
               Property            Mortgage            Real                           
               Situs               Interest            Property Taxes                 
          331 W. 46th St.          $10,913                  $245                      
          Salter Rd.             23,994               2,333                           
          8431 Hooper            11,085               1,320                           
          2232 Mortimer           3,426               2,367                           
          Chicot County              ---                  236                         
          Total                49,418              6,501                              








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