- 25 -                                         
          the Gownis reported a $45,000 loss from this sale on their 1998             
          return, the IRS adjusted the Gownis’ income to reflect this gain.           
                    2.  Corporate Distributions                                       
               The Gownis received and deposited into their personal bank             
          accounts checks from Ava Anthony, net of repayments, totaling               
          $13,640.  The IRS determined that the Gownis should have reported           
          this amount as dividend income.                                             
               The Gownis received and deposited into their personal bank             
          accounts checks from Tomson, net of repayments, totaling                    
          $101,000.  The IRS determined that these distributions were made            
          from sources other than the proceeds of the transaction between             
          Tomson and Sembler.  Therefore, the IRS determined that the                 
          Gownis should have included this amount in income.                          
                    3.  Other Income                                                  
               The Gownis received and deposited into their personal bank             
          accounts unexplained amounts of cash and checks from sources                
          other than their business entities or those reported on their               
          income tax return totaling $80,868.  The IRS determined that the            
          Gownis should have reported this amount on their 1998 return as             
          income from self-employment.                                                
               B.  1999                                                               
               The IRS made the following determinations with respect to              
          the Gownis for 1999:                                                        
Page:  Previous   15   16   17   18   19   20   21   22   23   24   25   26   27   28   29   30   31   32   33   34   NextLast modified: May 25, 2011