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Engineers, Inc. (FCE), of $10,501 and $10,300 respectively. On
his returns for 1990 and 1991, petitioner reported no income from
Paragon Construction Group, Inc. (PCG) in 1990 and $37,100 in
1991. After examining petitioner's returns, respondent
determined that petitioner underreported his income during the
years in issue. Relying primarily on the income figures listed
in two separate loan applications completed and signed by
petitioner, respondent determined that petitioner's total income
from FCE was $76,800 in 1988 and $76,800 in 1989 and that his
income from PCG was $70,902 in 1990 and $76,960 in 1991.
Loan Applications
The first loan application was completed by petitioner and
Mrs. Driggers in an attempt to finance the construction of their
new residence. Petitioner and Mrs. Driggers submitted a
Residential Loan Application on March 3, 1989 (1989 Application).
On the 1989 Application, petitioner listed his current gross
monthly income as $6,400, which translates to $76,800 per year
for 1989. In connection with the 1989 Application, petitioner
authorized his employer, FCE, to verify his employment. On the
Request for Verification of Employment form completed by FCE on
March 7, 1989, petitioner's current weekly salary is listed as
$1,476.92, which translates to $76,799.84 per year for 1989. In
addition, this verification form also lists petitioner's 1988
salary as $76,800.
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