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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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