Kamil F. and Nagwa Gowni - Page 19

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          have included an additional $14,030 in income as a result of                
          these distributions.                                                        
               The Mansours received and deposited into their personal bank           
          account at First Union checks from Mina of Sanford, net of                  
          repayments, totaling $31,750.  The IRS determined that Mina of              
          Sanford was an S corporation during 1996 and that the Mansours              
          had failed to establish their basis in their Mina of Sanford                
          stock.  Accordingly, because the Mansours reported income of                
          $10,524 from the operations of Mina of Sanford on their 1996                
          return, the IRS determined that the Mansours should have included           
          an additional $21,226 in income as a result of these                        
          distributions.                                                              
                    3.  Other Income                                                  
               The Mansours received and deposited into their personal bank           
          account at First Union unexplained amounts of cash and checks               
          from sources other than their business entities or those reported           
          on their income tax return totaling $138,235.  The IRS determined           
          that the Mansours should have reported this amount on their 1996            
          return as income from self-employment.                                      
               B.  1997                                                               
               The IRS determined that the Mansours received and deposited            
          into their personal bank accounts at First Union and SunTrust               
          unexplained amounts of cash and checks from sources other than              
          their business entities or those reported on their income tax               






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