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additional specific items of taxable income to petitioner. Of
the above checks, checks in the totals of $145,430 and $44,100,
respectively for each year, were either made payable directly to
petitioner or endorsed over to petitioner. Petitioner claims
that these specific checks relate to a stock trading scheme
involving petitioner and other individuals who transferred the
same funds back and forth to manipulate the price of stock, and
therefore that these checks should not be treated as taxable
income to petitioner. Petitioner has not presented credible
evidence of this alleged stock manipulation scheme, and the above
checks are to be treated as specific items of taxable income to
petitioner.
Certain additional checks in the totals of $332,430 and
$69,980 that were not deposited into petitioner’s bank accounts
in 1987 and 1988, respectively, and that were charged by
respondent to petitioner as additional items of specific income
were not made payable to petitioner. They were not endorsed over
to petitioner, nor were they deposited into petitioner’s bank
accounts. Respondent’s theory for charging these checks to
petitioner as specific items of taxable income appears to be that
on some of the checks petitioner’s name was written on the memo
line. Petitioner is not the indicated payee on these checks, and
the evidence does not establish that these checks benefited
petitioner. Funds represented by these checks are not to be
treated as constituting specific items of income to petitioner.
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