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police department, was assigned to investigate that purported
theft. Officer Coffey prepared a report with respect to the 1991
purported theft (police report) largely on the basis of informa-
tion provided by petitioner and/or Ms. Weber. The police report
included certain attachments that petitioner and/or Ms. Weber
prepared, which described the items that were allegedly stolen
from petitioner as a result of the 1991 purported theft and
assigned a monetary value to each of those items. In the course
of investigating the 1991 purported theft, Officer Coffey con-
tacted two other individuals in addition to petitioner and Ms.
Weber. With respect to the statements that Officer Coffey took
from those two individuals, Officer Coffey stated in the police
report:
Ofc Coffey contacted a business associate of * * *
[petitioner], Welch who stated that the tools were
loaded up onto a truck and moved to Montana by * * *
[petitioner’s] girlfriend as far as he knew. Welch
stated that he didn’t know who took the tools or he
didn’t have anything to do with it. * * * Ofc Coffey
called and contacted Melchert who stated that he was
only briefly aware of the theft and was not sure what
Ofc Coffey wanted. Melchert could only say that * * *
[petitioner] had a lot of tools and Melchert stated
that he thinks that $40,000.00 is a bit inflated. * * *
Officer Coffey recommended in the police report that the case “be
closed due to the time laps [sic] and no leads to follow up on.”
Form 1040, U.S. Individual Income Tax Return (Form 1040),
for 1995 (1995 return) was filed with respondent in petitioner’s
name and signed in petitioner’s name. The 1995 return showed
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Last modified: May 25, 2011