John R. Hernandez - Page 10

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               “J. Campbell” was a friend of petitioner.  Petitioner                  
          testified at trial that Mr. Campbell was a “coventurer” in                  
          respect of the certificates issued in their names.  Respondent              
          did not include in petitioner’s income $737.50 of interest                  
          received in 1990 on the ground that that interest was attributed            
          to Mr. Campbell.  In 1992, respondent attributed $3,569.85 to               
          Mr. Campbell, or half the interest income reported on the Form              
          1099 to “J. Campbell or J. Hernandez” for that year.                        
               Every check issued in redemption of the tax certificates at            
          issue, and listed in the amounts described above, was deposited             
          in an account at Florida Federal Savings & Loan Association in              
          Mrs. Hernandez’ name to which petitioner had access, including              
          those amounts not contained in respondent’s adjustments to                  
          petitioner’s income.                                                        
               On September 19, 1991, petitioner and Mrs. Hernandez filed             
          a joint income tax return for tax year 1990.  On September 18,              
          1992, petitioner and Mrs. Hernandez filed a joint income tax                
          return for tax year 1991.  On October 28, 1993, petitioner and              
          Mrs. Hernandez filed a joint income tax return for tax year 1992.           
               On August 26, 1994, petitioner and Mrs. Hernandez signed a             
          Form 872, printed by the Government Printing Office on green                
          paper, consenting to extend the period of limitations for tax               
          year 1990 until December 31, 1995.  Respondent’s authorized agent           
          signed the form on August 29, 1994.  On March 20, 1995,                     





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