- 28 -
listed for 1989 or 1990. The net payments to clients in
this category are as follows:
1989 1990
Steven Dana $-500.00 -0-
Said Dermarkar -0- $-2,000.00
Carissa Drucker -1,671.03 -4,010.00
Stewart Gleischman -458.82 -18,740.08
Jepsco/Epstein -4,721.00 -30,010.00
Joblon -0- -1,128.13
-7,350.85 -55,888.21
The above schedule also shows that petitioner allegedly
made payments to a number of clients, including his
parents, that substantially exceeded the amount of fees
petitioner received from those clients. The net payments
to clients in this category are as follows:
1989 1990
Faith Burns -$2,980.91 -0-
Eric Friedmann 3,788.01 -$8,722.94
Bill Habelow -5,687.75 -2,350.00
Jeff Kolton 3,772.00 -12,500.00
Margaret Lynch -26,697.70 -0-
Another preliminary point should be noted. In his
reply brief, petitioner implies that he was unable to
produce some records necessary to substantiate the "returns
and allowances" reported on his returns because certain of
his records had been lost. In discussing the evidence that
he adduced to substantiate the direct payments, petitioner
states that his "business records were lost when he shipped
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