John Wadsworth - Page 13

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          years in issue, Agent Christenot checked the Ventura County,                
          California, court records, where petitioner lived, to identify              
          any real estate or other property owned by petitioner and found             
          nothing in those court records pertaining to petitioner.                    
               The IRMF report is a report that is compiled by the IRS on             
          all payment of mortgage interest.  It is compiled in Michigan               
          from Forms 1098, Mortgage Interest Statements, that are forwarded           
          to IRS from financial institutions throughout the country.  The             
          Forms 1098 list all mortgage payments made throughout the country           
          and that information is aggregated in one main computer program             
          maintained by the IRS in the State of Michigan.                             
               Agent Christenot was able to learn through the IRMF that               
          petitioner had made mortgage interest payments for the years 1989           
          through 1992 in the amounts of $11,896, $11,288, $6,466, and                
          $4,005, respectively.  Respondent introduced into evidence at               
          trial documentation showing that petitioner and Charlotte                   
          executed a deed of trust on May 12, 1975, in favor of Valley                
          Federal Savings and Loan Association in which they pledged their            
          home at 2600 Valley Meadow Court as security for a $65,000                  
          promissory note.                                                            
               Respondent then computed petitioner's taxable income on the            
          basis of the BLS for the years in issue.  The BLS represents                
          estimates of petitioner's annual living expenses.  The categories           
          of family consumption include food, housing, transportation,                
          clothing, personal care, medical care, and other consumables.               




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