Kamil F. and Nagwa Gowni - Page 21

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          Enterprises stock.  Accordingly, because the Mansours reported              
          income of $13,000 from the operations of Mansour Enterprises on             
          their 1998 return, the IRS determined that the Mansours should              
          have included an additional $9,600 in income as a result of these           
          distributions.                                                              
                    3.  Other Income                                                  
               The Mansours received and deposited into their personal bank           
          account at SunTrust unexplained amounts of cash and checks from             
          sources other than their business entities or those reported on             
          their income tax return totaling $122,853.  The IRS determined              
          that the Mansours should have reported this amount on their 1998            
          return as income from self-employment.                                      
               D.  1999                                                               
               The IRS made the following determinations with respect to              
          the Mansours for 1999:                                                      
                    1.  Disallowance of Long-Term Capital Loss Carryover              
               The long-term capital loss carryover of $3,430 that was                
          reported on the Mansours’ 1999 return was disallowed because it             
          resulted from their reporting a capital loss rather than a                  
          capital gain from the transaction between Tomson and Sembler on             
          their 1998 return.  The IRS adjusted the Mansours’ income to                
          account for this disallowance.                                              









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