Dwight L. McKenna and Beverly S. McKenna - Page 5

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            contributions, and he was required to file a report declaring                               
            those contributions.  He made copies of each check for purposes                             
            of reporting the contributions on the report.  He reported the                              
            total amount of his contributions.                                                          
            Petitioner's Medical Practice in 1987 and 1988                                              
                  For 1987 and 1988, petitioner's income and expenses of his                            
            medical practice were reported on Schedule C, Profit or (Loss)                              
            From Business or Profession.  He was the stated proprietor.                                 
                  During 1987 and 1988, and for several prior years, many of                            
            petitioner's patients were referred to him by personal injury                               
            attorneys.  These patients had been involved in some type of                                
            accident and required medical attention.  Petitioner would                                  
            generally treat each patient and send the patient's bill directly                           
            to the patient's attorney.  He received payments for these                                  
            services from the patient's attorney, and the payments were taken                           
            from the settlement proceeds of, or recoveries from, the personal                           
            injury case.                                                                                
                  In 1987 petitioner received 990 checks from 63 attorneys,                             
            insurance companies, and governmental agencies, in the total                                
            amount of $577,285.94.  He knew that each of these checks was                               
            income to him.                                                                              
                  In 1988 petitioner received 864 checks from 65 attorneys,                             
            insurance companies, and governmental agencies, in the total                                








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