Gary Friedmann - Page 26

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             allowances, at trial petitioner was unable to itemize the                
             fees composing the gross receipts reported on his Schedules              
             C for 1989 and 1990.  The totals from the two lists of fees              
             that petitioner introduced at trial do not match the gross               
             receipts reported on the Schedules C filed with his                      
             returns.                                                                 
             In any event, for both of the years in issue, the                        
             following schedule repeats the lists of fees that                        
             petitioner introduced at trial, it shows the payments                    
             allegedly made by petitioner to, or on behalf of, each of                
             his clients, and it shows the net amounts for each client:               

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