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          signed the sales contract.  Petitioner did not report any income            
          from this sale on his Form 1040 for 1988.                                   
               The record contains two personal financial statements for              
          petitioner.  The first is dated November 15, 1985, and lists as             
          an asset, East Lake Vista;27 a “160 acre parcel located on East             
          Lake North of Narcoossee being subdivied [sic] into 5 ac. tracts            
          and is encumbered by 2 mortgages totaling $386,000.00”.  The                
          listing states:  “I own 1/2 interest”, and values that interest             
          at $560,000, subject to liabilities of $193,000.  The second                
          financial statement is dated June 1, 1988, and lists as an asset,           
          East Lake Vista; a “100 acre parcel located on East Lake North of           
          Narcoossee being subdivided into 5 ac. tracts”.  That property is           
          listed under “Miscellaneous Lots & Acreage (Unencumbered)” and is           
          valued at $400,000.                                                         
               Mr. Miles’s law firm maintained certain ledger cards,                  
          numbers 70006 through 70008, which are entitled “Walter                     
          Medlin/Reba Smith”, “Medlin  Re:  Smith, Reba”, and “Medlin,                
          Walter from Reba L. Smith”, respectively.  Those ledger cards               
          contain the following relevant entries:                                     
               27Petitioner testified that East Lake Vista is also known as           
          the “Narcoossee property” and the “Dan Smith Road property”.  The           
          parties also agree that the property was sometimes called the               
          “Reba Smith property”.                                                      
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