Robert J. Geary - Page 6




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          capitalize on the resultant publicity to develop commercial                  
          interest in his unique patrol ideas.                                         
               Interscope paid petitioner $10,000 under the contract for               
          consulting services in connection with the development of a                  
          screenplay, which income petitioner reported as wage income on               
          his 1993 Federal income tax return.6  Petitioner also received               
          $4,500 from Golden Door Productions, the movie studio which                  
          helped petitioner sell his idea to Interscope, and $2,216 from               
          miscellaneous sources for various appearances as a "hand model"              
          and as an "entertainer".  Petitioner reported these                          
          amounts, a total of $6,716, on Schedule C attached to                        
          his 1993 Federal income tax return.  Petitioner claimed an                   
          $11,465 advertising expense deduction on Schedule C representing             
          petitioner's total ballot expenditures for Proposition BB.7                  




          6    Petitioner is still under contract with Interscope.  If                 
          Interscope exercises the option and a movie is ever made,                    
          petitioner will earn $25,000 as a consultant, plus 15 percent of             
          the fee which would be paid to the producers of the film, and 33             
          percent of the profits to be paid to the producers from any                  
          assignment of the story.                                                     
          7    This amount includes $9,711.49 for signature gatherers,                 
          $1,200 in contributions to local political organizations that                
          endorsed Proposition BB on their local slates, and other                     
          miscellaneous expenses.  Though petitioner only claimed as                   
          advertising expenses the amount of $11,465 on Schedule C of his              
          1993 Federal income tax return, the parties stipulated that                  
          petitioner incurred total ballot expenses in the amount of                   
          $11,645.  The difference between these two numbers seems to be a             
          transpositional error.                                                       




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