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increased if necessary. Reimbursement for advances
will be facilitated through subsequent collections.
The credit facility that CMS had in place with Signet at
that time was in the amount of $300,000; however, the Signet
credit facility could not be used in connection with prospective
GNMA business, nor was it subject to increase.
Many years prior to the year in issue, petitioner had been
employed for a brief period of time as a staff attorney for a
company involved in marketing franchises and other securities.
As a result of this employment, petitioner was named as a
defendant in a law suit brought by certain clients or customers
of this company under various provisions of the Securities Act of
1933. Petitioner was named as a defendant in the suit merely
because his name appeared on the letterhead of his former
employer. Although the outcome of that proceeding has not been
made part of the record, it does not appear that petitioner
incurred any liability as a result of it.
Petitioner's 1990 Federal Income Tax Return
CMS issued a Form W-2 for the year 1990 to petitioner
reflecting wages in the amount of $45,751.20. Federal income tax
and FICA withholdings were computed based upon the entire amount
and withheld. On his 1990 Federal income tax return, petitioner
reported wages of $25,751.20. In an attachment to his 1990
return, petitioner explained that $20,000 of the amount he
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