Myron Barlow and Arlene Barlow - Page 19




                                        - 19 -                                         
                         Year            Compensation                                  
                         1982              $294,263                                    
                         1983               348,630                                    
                         1984               250,000                                    
                         1985               356,590                                    
               During the years in issue, petitioner Arlene Barlow was not             
          generally employed outside the home.  She did receive some                   
          minimal compensation in 1984 and 1985 working for petitioner’s               
          professional corporation.                                                    
               Petitioner is also a sophisticated investor.  Prior to                  
          purchasing a partnership interest in Dickinson, petitioner’s                 
          investment portfolio included a variety of interests.  For                   
          example, petitioner owned stock in a closely held corporation,               
          DOTT Manufacturing Co., that formed plastic products for the                 
          automobile industry.7  Petitioner also owned partnership                     
          interests in Wilmington Associates, a “land type of investment”              
          in North Carolina; 16-75 Land Co., “an investment in an office               
          building” in Michigan; and Stonebridge Manor Properties, a                   
          partnership whose business is not described in the record.                   
          Petitioner also owned an interest in Greater Mary, an operating              
          coal mine in Pennsylvania.  In addition, petitioner owned stocks             
          and bonds, including municipal bonds, as well as a communications            
          system that he rented to a medical clinic.                                   



               7  On their income tax return for 1985, petitioners reported            
          gain from the sale of stock in Dott in the amount of $222,349,               
          based on a gross sales price of $287,034 and cost or other basis,            
          plus expense of sale, in the amount of $64,685.                              





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