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joint checking account; checks written on the account bore her
signature only.
According to the October 30, 1996, letter, the family home
had originally been titled jointly in the name of petitioner's
mother and father. The letter states that when petitioner's
father died in 1982, petitioner's mother added petitioner's
sister's name to the home mortgage held by Great Western Mortgage
Co. On August 1, 1989, petitioner's sister caused to be recorded
a "grant deed" (copy attached to the letter of October 30, 1996)
conveying "her joint tenancy interest" in the home to her mother,
but Great Western Mortgage Co. refused to remove the sister's
name from the mortgage as a joint borrower.
Petitioner and his mother in 1990 and 1993 jointly borrowed
$27,000 and $74,000, respectively, from Household Finance Corp.
of California evidenced by deeds of trust (copies attached to the
letter of October 30, 1996).
Sent with the October 30, 1996, letter was a copy of a 1993
Federal income tax return for petitioner's mother, Jeanette
Mills, in which she reported adjusted gross income of $2,816, a
copy of a compilation listing church contributions in her name,
and a copy of a handwritten worksheet "showing support" of the
three children of petitioner's sister.
On November 7, 1996, about a week after receiving
petitioner's October 30, 1996, letter, respondent's Appeals
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