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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.
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