David M. Leggett - Page 3

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          in the amounts of $52,456, $60,970, $74,925, and $79,360, re-               
               On January 24, 1995, petitioner and Biddle executed what               
          purported to be a contract which was entitled "CONTRACT BETWEEN             
          TRADESMAN/LABORER/CRAFTSMAN AND PROPERTY OWNER".  That document             
          stated in pertinent part:                                                   
               In the absence of "real" money (commodity money), the                  
               TRADESMAN [petitioner] offers to trade his property at                 
               the rate of _________ Federal Reserve Notes (FRN's) for                
               each hour of labor expended on behalf of the PROPERTY                  
               OWNER [Biddle].  The TRADESMAN does not receive the                    
               FRN's as equal trade value for his property, but for                   
               the potential opportunity to trade said FRN's for                      
               something of actual value.  However, the PROPERTY OWNER                
               is immediately, upon receipt of the FRN's by the                       
               TRADESMAN, relieved of any further obligations to the                  
               TRADESMAN for the labor for which said FRN's were                      
                        *    *    *    *    *    *    *                              
               TRADESMAN is specifically NOT the employee of the                      
               PROPERTY OWNER, nor is he an "independent contractor".                 
               During 1992 and 1993, petitioner received taxable interest             
          income from Great Western Bank in the amounts of $149 and $88,              
          respectively.  During 1992, he also received self-employment                
          income from NTS Sabal Golf Villas in the amount of $181.                    
               Biddle and the other payors of income to petitioner during             
          the years at issue reported the payment of such income to the               
          Internal Revenue Service (Service).                                         
               Petitioner made estimated tax payments for 1992 in the                 
          amounts of $1,800, $2,000, and $2,500 on April 20, 1992, June 20,           
          1992, and September 23, 1992, respectively.  Petitioner made no             

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