Gerald A. Bunker - Page 5

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          Service (IRS) and issued petitioner information returns3 as                 
          follows:                                                                    
                    Issuer         Reporting form           Amount                    
               American Security        1099-C         $11,396.09                     
               Capital One Bank    1099-MISC, Box 7       $4,448.00                   
          TOTAL                                    $15,844.09                         
          However, at trial respondent produced evidence to substantiate              
          payments from American Security of only $10,800.  Respondent’s              
          counsel admitted that he did not know how the amount of $11,3964            
          was calculated by American Security.  Therefore, respondent                 
          conceded the difference in payments of $596.  As a result,                  
          $15,248 is the total amount of unreported income remaining at               
          issue.  Petitioner did not include these amounts as income in his           
          Federal income tax return for 2001.  In the notice of deficiency,           
          respondent determined that these amounts constituted gross                  
          income.                                                                     












          3Petitioner claims that he did not receive the applicable                   
          Forms 1099; however, petitioner admitted that he was aware that             
          such payments were being made during tax year 2001.                         
          4Amount rounded to the nearest dollar.                                      




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