Sam F. and Ingrid D. Ford - Page 11

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               of deficiency for the taxable year 1986, are the identical             
               shares of Tillex and Beverly Development stock which Marc              
               Ford purportedly sold in 1986.                                         
                    The circumstantial evidence linking petitioner Sam                
               Ford's admitted unreported income for the year 1986 in                 
               excess of $2.8 million from the sale of securities he                  
               secretly held in the names of such nominees as Marc                    
               Ford, the Tillex and the Beverly Development stock                     
               purportedly sold in 1986 by Marc Ford when it belonged                 
               to petitioner Sam Ford, and the capital gains                          
               adjustment for the disposition of the Tillex and the                   
               Beverly Development stock in the statutory notice is                   
               In that response, respondent also listed five items of                 
          circumstantial evidence to which respondent referred above.  The            
          first item is petitioner's admission in his allocution that he              
          had failed to report income of $2.8 million "which I had secreted           
          in the name of my son and others."  The second item is a                    
          probation officer's report indicating that between 1984 and 1987            
          petitioner received "income from the sale of shares of Tillex               
          stock which netted $2,500,000 in profits."  The third item is the           
          adjustment for capital gains contained in the statutory notice of           
          deficiency indicating that petitioners had failed to report                 
          capital gains from the sale of stock in Tillex and Beverly                  
          Development in the total amount of $5,084,483, with a resulting             
          increase in taxable income of $2,341,878.  The fourth item is               
          respondent's indication that, at the trial of the instant case,             
          petitioner's son Marc Ford would testify that he sold stock in              
          Tillex and Beverly Development during 1986 for a net gain of                
          $2,807,704.  The fifth item was a citation of petitioners'                  

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