- 22 -                                         
                    Summary of Income Tax Changes by Notice of Deficiency             
                          and Agreed Computation of Deficiencies                      
             Adjustments to Income--                      Years Ending                
             Notice of Deficiency                  12/31/88   12/31/89   12/31/90     
             A.  Agreed item--adjustment to                                           
             income from the Houston firm           $4,593                            
                                                                                     
             B.  Schedule F income                                                    
             (cattle feeding business)             46,000                             
             C.  Schedule F expenses                                                  
             (cattle feeding business)             9,803                              
             D.  Schedule E passive activity loss                                     
             (loss from condominiums)              1,827    $1,305     $660           
             E.  Income                                                               
             (payments by the Houston                                                 
             firm of partnership interest)         304,649  552,218  617,482          
             F.  Whipsaw adjustment to income                                         
             (related to income from the                                              
             Houston firm)                                          (166,667)         
             G.  Partnership expense (claimed                                         
             as offset to petitioner's                                                
             income from the Houston firm)         140,935                            
             H.  Other gains and losses                                               
             (from sale of airplane)                        (17,403)                  
             I.  Constructive dividend                                                
             (life insurance proceeds)                      190,943                   
             J.  Schedule C expenses (disallowed                                      
             expenses attributable to                                                 
             Corpus Christi office)                         208,570    61,267         
             K.  Schedule K-1 1120S flow-through                                      
             (disallowed expenses from                                                
             professional corporation)                              54,929            
             L.  Capital gains and losses (disallowed                                 
             capital loss carryover and losses                                        
             claimed for worthless stock in                                           
             Cooper's Alley & Compuprint and                                          
             disallowed capital gains claimed                                         
             for sale of partnership interest                                         
             in the Houston firm)                  3,000    (314,272) (535,018)       
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