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July 31, 1996 check by endorsing it to an individual named Gayle
Bjorkland.
Sale of Petitioner’s Arcade Games
Around May 1, 1996, petitioner sold 10 arcade games (arcade
games) to Reality Entertainment, a company located in Des Moines,
Iowa. Petitioner and Mr. Robinson delivered those arcade games
to Reality Entertainment. Reality Entertainment financed the
purchase of the arcade games through Norwest Equipment Finance,
Inc. (Norwest Equipment Finance), a company located in Minneapo-
lis. On May 1, 1996, Norwest Equipment Finance issued a $16,450
check (May 1, 1996 check) payable to petitioner and drawn on its
account at Norwest Bank-Minneapolis as payment to petitioner for
the sale of the arcade games (petitioner’s sales proceeds from
the sale of the arcade games). Petitioner endorsed the May 1,
1996 check and sent it to Mr. Kallestad at Weavewood, which Mr.
Kallestad received on or about May 6, 1996. On May 6, 1996, at
petitioner’s request, Mr. Kallestad arranged through Norwest Bank
of Wayzata, Minnesota, to have petitioner’s sales proceeds from
the sale of the arcade games wired to petitioner at Caesar’s
Tahoe casino.
Ms. Thompson’s Tax Returns
for 1994, 1995, and 1996
Ms. Thompson filed Form 1040, U.S. Individual Income Tax
Return (Form 1040), for each of her taxable years 1994 (Ms.
Thompson’s 1994 return), 1995 (Ms. Thompson’s 1995 return), and
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