Nick Kikalos and Helen Kikalos - Page 15

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          promotional income and that his gross income was understated by             
          $53,179.  The $69,915 amount is composed of three components.               
          The first and second components are $5,452 of “8 cent coupon”               
          income and $523 of postage income.  Petitioner reported the                 
          $5,452 of “8 cent coupon” income as a portion of the total                  
          $16,736 of promotional income reported on his 1997 return.                  
          Petitioner conceded that he failed to report $523 in postage                
          income.                                                                     
               The remaining $63,940 (third component) was derived from the           
          worksheets provided by petitioner.  The rack and promotional                
          income shown on all four worksheets totaled $63,940.  Respondent            
          points out that petitioner’s promotional contract with R.J.                 
          Reynolds was in effect during 1997, a fact that supports                    
          respondent’s determination.  Petitioner argues that the                     
          worksheets are unreliable due to the fact that he was in the                
          process of learning how to use a computer and made input errors.            
          In addition, petitioner asserts that the R.J. Reynolds                      
          promotional contract was not in effect during 1997 and that he              
          did not receive any payments under the contract.                            
               During 1997 petitioner received a check from R.J. Reynolds             
          for $13,164, the quarterly amount called for in the promotional             
          contract.  Although the record does not reflect the specific                
          purpose for the payment, it coincides with the amount called for            
          in the promotional contract.  Quarterly payments of $13,164 would           






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