Terri L. Steffen - Page 5




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                         Item                     Amount                              
                         Bilzerian & Mack         $1,840,003                          
                         Bilzerian Investors      10,216,579                          
                         Bilzerian Ventures       3,107                               
                         Personal Gain            4,170,093                           
                         Total                    16,229,782                          
               On June 15, 1987, petitioner and Mr. Bilzerian signed and              
          filed a Form 4868, Application for Automatic Extension of Time to           
          File U.S. Individual Income Tax Return, for the taxable year                
          1986, along with a payment of $5 million.  Petitioner and Mr.               
          Bilzerian were in possession of the schedule prepared by Peat               
          Marwick at that time, and Mr. Bilzerian discussed their estimated           
          tax liability payment with petitioner.  On August 12, 1987,                 
          petitioner and Mr. Bilzerian filed a Form 2688, Application for             
          Additional Extension of Time To File U.S. Individual Income Tax             
          Return.                                                                     
               On October 15, 1987, petitioner and Mr. Bilzerian filed                
          their 1986 Form 1040, U.S. Individual Income Tax Return.  On                
          Schedule E, Supplemental Income and Loss, they reported the                 
          following net income from Mr. Bilzerian’s stock dealings in                 
          Hammermill:                                                                 
                         Item                     Amount                              
                         Bilzerian & Mack         $1,840,003                          
                         Bilzerian Investors      10,216,579                          
                         Bilzerian Ventures       3,107                               
                         Total                    12,059,689                          
          On their Schedule C, Profit or Loss From Business, petitioner and           
          Mr. Bilzerian reported gross income of $8,063,277 from the sale             







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