- 101 -                                        
          Petitioner maintains that checks he gave respondent’s counsel               
          during trial preparation compared with cash disbursement                    
          spreadsheets included in certain workpapers in evidence show that           
          the rent payments did not go to him but instead went to third-              
          party commercial rental agents that rented space to branch                  
          offices of IL NA Tours.                                                     
               Respondent contends that petitioner has not shown that IL NA           
          Tours and Air America did not pay him rent during 1988.                     
          Respondent asserts that the evidence on which petitioner relies             
          is not relevant to the issue of rental payments made by IL NA               
          Tours and Air America to him because none of the checks or cash             
          disbursement recordations relate to payments for space used by IL           
          NA Tours or Air America.                                                    
               Respondent asserts further that the checks petitioner                  
          submitted do not add up to the $53,552 in total that Air America            
          and IL NA Tours deducted as rental expense on their corporate               
          returns.  Respondent contends that petitioner’s pattern of taking           
          money from his corporations belies his claim that he passed up an           
          opportunity to take rental income from his corporations,                    
          especially when his activities were being carefully monitored by            
          Northwest.                                                                  
               We are persuaded on the basis of the record that petitioner            
          was in error when he informed the revenue agent and respondent’s            
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