Robert L. Beck - Page 10

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               In 1994, Mrs. Beck deposited approximately $11,691 into her            
          separate account, mostly in cash.  In 1995, she made deposits of            
          approximately $54,616 into the separate account, mostly in cash.            
          The primary source of these deposits was income from the dental             
          practice.  In 1994, Mrs. Beck made cash deposits totaling at                
          least $6,120 to petitioners’ joint account.                                 
               From 1977 through September 1995, Dr. Beck, either singly or           
          with his former wife, E. Roman Beck, owned or controlled the                
          ownership of more than 100 acres in Blanco Hills County Estate in           
          Bexar County, north of San Antonio, Texas (the Blanco property).            
          In a foreclosure sale on October 3, 1995, the Blanco property was           
          sold to an unrelated third party for $290,000.  On October 15,              
          1995, Mrs. Beck purchased the Blanco property from the third                
          party, in exchange for a note in the principal amount of                    
          $331,845, executed by Mrs. Beck and secured by a lien on the                
          Blanco property.  Mrs. Beck used income from Dr. Beck’s dental              
          practice to purchase the Blanco property.                                   
          Petitioners’ Tax Returns                                                    
               Dr. Beck filed no Federal income tax returns for taxable               
          years 1991 through 1994 until September 1, 1995.6  For each year            

               6 Dr. Beck was granted extensions to file Federal income tax           
          returns for each of the taxable years in issue and filed his                
          returns on the dates indicated below:                                       


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