- 79 - No. 121 on her checking account for $13,167.96 as a payment of interest on the loan and delivered it to Brown sometime between December 22, 1987, and February 12, 1988. The check was dated December 22, 1987. The check was posted to Markette’s bank account on February 12, 1988, and to Betsy’s checking account on February 16, 1988. Betsy wrote checks in her checking account in numerical order. Check No. 120 was recorded on Betsy’s checking account register on November 30, 1987, and check No. 122 was recorded on June 25, 1988. Starting in December 1987, Betsy and Brown began to pack up the Sley Corporations books and records in boxes because they were going to move the Sley Corporations office out of the Grossman & Flask sublet office space. Betsy arranged to have professional movers move the Sley Corporations office on January 13, 1988. On their 1987 joint tax return, petitioner and Betsy listed a $13,168 personal interest expense to Markette and deducted 65- percent of it--$8,559--as an itemized deduction on Schedule A. Respondent disallowed this deduction. For each of the years 1983 through 1986, petitioner had an underpayment of income tax required to be shown on his tax return; some part of the underpayment for each of the years 1985 and 1986 was due to petitioner’s fraud.Page: Previous 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 Next
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