Beatrice DiPierro - Page 4




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          received a payment of $30,000 in discharge of the remaining                 
          obligation under the $120,000 note.                                         
               At the time of trial, petitioner still owned three of the              
          California rental properties.  During 1992 and 1993, two of those           
          properties rented for between $675 and $750 a month and one                 
          rented for between $525 and $550 a month.  Petitioner sold the              
          fourth California rental property in October 1992, receiving a              
          note in the principal amount of $110,000, calling for monthly               
          payments of $945.  Prior to its sale, the fourth California                 
          property rented for between $575 and $625 a month.  Most of the             
          rental payments petitioner received with respect to the                     
          California properties were received in cash, collected by her or            
          her son, Gary.  When Gary collected the rental payments, he                 
          deposited them in a bank account petitioner maintained in                   
          California, and she would write checks on that account.                     
          Petitioner relied on her memory to report her rental receipts to            
          her accountant (who prepared her Federal income tax return).                
               In April 1990, petitioner purchased a two-bedroom                      
          condominium apartment in Las Vegas, Nevada (the Las Vegas                   
          property), for $145,000, in cash.  She obtained that sum from the           
          proceeds of the sale of the Dunedin property and a loan of                  
          $110,000 from NCNB National Bank.  The Las Vegas property was               
          held for rental, for between $800 and $1,100 a month.                       







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