Jerry S. Payne - Page 44

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          proves otherwise by a preponderance of the evidence.  Sec.                  
          6653(b)(2).                                                                 

                    Corrected Income and Deductions for 1987 and 1988                 
               The following schedules reflect for 1987 and 1988 our findings         
          and conclusions as to petitioner's correct total income and                 
          deductions including income previously reported by petitioner and           
          deductions previously allowed by respondent:                                

          Items of Income for 1987                                                    
          Description                                            Amount               
          Conceded Bank Deposits                                 $234,453             
          Conceded Checks Made Payable to Petitioner             20,311               
          Bank Deposits Relating to Payne & Potter          12,826                    
          Miscellaneous Bank Deposits and Other Checks           16,932               
          Cash Withdrawals from the Club                         6,721                
                                            Total          $291,243                  

          Deductions Allowed for 1987                                                 
          Description                                            Amount               
          Allowed Business Deductions:                                                
               Business Interest                                 $32,063              
               Depreciation/Lakeway                              4,890                
               Miscellaneous                                     48,870               
          Allowed Itemized Deductions:                                                
               Mortgage Interest                                 15,965               
               Taxes                                             2,697                
          Nonbusiness Bad Debt Relating to Guaranty              3,000                
                                            Total               $107,485             












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