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report them as tax-exempt interest as required by section
6012(d). In those instances in which the alternate payee did
report such amounts as either income or interest excludable from
income under section 103, respondent did not include those
amounts in petitioner’s income.
With respect to amounts that petitioner claims were income
to Mark Craig, petitioner proffered in evidence a letter from his
daughter--Mark’s mother, Mrs. Craig--claiming that petitioner was
holding these amounts “as agent for * * * [Mrs Craig] and * * *
[her] minor children”. Mrs Craig did not testify at trial.
With respect to amounts of interest received from the
redemption of certificates held in his or Mrs. Hernandez’ name
and those of Vincent or Mildred Hernandez, respectively,
petitioner produced no evidence that such amounts were not his
income other than a document signed in 1984 by Vincent and
Mildred Hernandez purporting to give petitioner a power of
attorney. Neither Vincent nor Mildred Hernandez testified at
trial. With respect to the remaining persons whose names
appeared on the tax certificates as alternate payees, petitioner
produced no evidence at all.
Unlike the taxpayer in the “Mexican Lottery Case”, Diaz v.
Commissioner, 58 T.C. 560, 565 (1972), whose grandmother, “face-
to-face with her priest in the courtroom”, corroborated every
word of his testimony that the lottery tickets in question
belonged to his uncle, petitioner failed to bring a single
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