T.P. and Najieh R. Crigler - Page 8




                                        - 8 -                                         
          Total from                    Total from                                    
               nonoperating sources              other sources                        
          1990            $89,572                       $3,000                        
          1991            351,529                        5,000                        
          1992             26,293                      250,000                        
          1993             19,443                      127,220                        
          1994                304                       22,312                        
          Totals        487,141                      407,532                          
               1 FabuGlass did not report this item on its 1991 tax return.           
          However, the parties stipulated to the contract which shows that            
          FabuGlass received $5,000 in 1991 from a real estate sale.                  
               2 The parties stipulated that FabuGlass received rent                  
          receipts of $14,779 in 1992.                                                
               Sawyer prepared FabuGlass’ tax return for 1995.  Petitioner            
          gave Sawyer a summary of income, expenses, and various                      
          transactions (e.g., sales of stock and real property) to use in             
          preparing the 1995 return.  FabuGlass reported that it was an               
          investment company.  FabuGlass reported the following on its 1995           
          return:              Assets and Liabilities                                 

                                           Beginning                                  
                Item                        of year     End of year                   
                Cash                     --            $396                           
                Inventories              $166,353      166,353                        
                Depreciable,             3,075         3,075                          
                depletable, and                                                       
                intangible assets                                                     
                Total assets             169,428     169,824                          
                Loans from stockholders  2,026,017     2,431,761                      
                Capital stock            430,258      25,000                          
                Retained earnings        (2,286,847)  (2,286,937)                     
                Total liabilities and    169,428       169,824                        
                stockholders’ equity                                                  





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