Ronald McDougle - Page 3




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          $43,622 and $4,852, respectively, and gambling winnings from                
          Western Village Associates in the amount of $1,282.                         
                                       OPINION                                        
               Petitioner does not challenge the facts on which                       
          respondent's determinations are based, nor the calculation of               
          tax.  Petitioner's argument is merely that he is not properly               
          subject to tax and is not required to file Federal income tax               
          returns.                                                                    
               Petitioner submitted documents, including six letters signed           
          by purported "tax professionals", in support of his argument.               
          These letters were from:                                                    
               Sherwood T. Rodrigues                                                  
               Certified Public Accountant (Ohio)                                     
               Sunnyvale, California                                                  
               Michael L. Kailing                                                     
               Tax Accountant                                                         
               Honolulu, Hawaii                                                       
               Guy G. Curtis*                                                         
               Attorney at Law                                                        
               Imperial, Nebraska                                                     
               *Petitioner introduced two letters from Guy G. Curtis, Attorney at Law.
               William T. Conklin, M.A.                                               
               Communication & Language Expert                                        
               Denver, Colorado                                                       
               Fred M. Ortiz                                                          
               Tax Consultant                                                         
               Kailua-Kona, Hawaii                                                    









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