Steven K. Han - Page 49





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               IL NA Tours did not file any Federal income tax returns                
          after its 1988 return.                                                      
               Air America filed returns for 1988 and 1989, but not for the           
          years 1990 through 1995.                                                    
               Neither Air America’s nor IL NA Tours’ returns for 1987 or             
          1988 reported any transactions related to the brokerage accounts            
          under individual names to which Northwest had traced corporate              
          funds.  Regarding those brokerage accounts, for 1987 petitioner             
          reported on his return selected transactions relating only to his           
          FCIS account, his Allied account, and various other brokerage               
          accounts not at issue in this case.  For 1988, petitioner                   
          reported only selected sales of stock in his FCIS account, his              
          Allied account, and P-B No. 1 on his return.                                
          Dividend Income Issue                                                       
               During 1988, the following amounts of dividend income were             
          paid on stocks held in the accounts noted:  $3,525 in Chung No. 1           
          (on March 1), $211 in Chung No. 3, $4,500 in the FCIS account (on           
          April 4, 1988), $16,905 in the Sam Han account, and $8,412 in P-B           
          No. 2 (during March 1988).                                                  
               Petitioner reported no dividend income on his 1988 return.             
          Interest Income Issue                                                       
               On January 30, 1989, Belofsky forwarded Forms 1099, Interest           
          Income, to Chung which reported that ANB Nos. 1 through 4 had               






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