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a company, Latin Credit Corporation (LCC), to help members of the
Hispanic community obtain car loans at a low rate. On July 15,
1988, LIC issued a check for $60,000 to LCC. The check contained
the signature of two drawers, including the signature of
petitioner.
Petitioner also was vice president of L&L Construction
Company (L&L). L&L was located in the same building as LIC.
Petitioner was paid compensation of $24,000 from L&L in 1988.
During 1988, petitioners deposited into two bank accounts
checks from L&L totaling $20,896. The checks were dated at
regular intervals. Checks written in January, February, and
March 1988 were payroll checks identifying petitioner as
"Employee No. 021". From April through December 1988, checks for
$500 and $1,000 were marked "Professional services".
Petitioners purchased a home on Labbe Lane in Vienna,
Virginia, in 1988. Mrs. Leonzo's brother, Jose Ayala (Ayala),
operated a carryout food business and pool hall out of a property
located at 3110 Mt. Pleasant.
Petitioners timely filed Forms 1040, U.S. Individual Income
Tax Returns, for 1988 and 1989. Petitioners' 1988 and 1989
returns each included a Schedule A, Itemized Deductions, and a
Schedule C, Profit or Loss from Business.
Petitioners claimed $12,992.51 for home mortgage interest
and $1,190.76 for personal interest on their 1988 Schedule A.
Petitioners substantiated $10,415 of the home mortgage interest
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