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The evidence presented by petitioner regarding the
payments totaling $21,679.75 consists of petitioner's
testimony, copies of canceled checks, and a copy of a check
stub. Petitioner testified that he made three separate
payments on behalf of Dr. Strom in order to avoid penalty
and interest charges that Dr. Strom had incurred in prior
years for late fee payments and tax deposits. According
to petitioner's testimony and the copies of the canceled
checks petitioner offered as evidence, petitioner paid
$2,679.75, on September 26, 1990, to the City of Beverly
Hills for Dr. Strom's personal medical licensing fee, he
paid $12,000 to the U.S. Department of the Treasury on
October 1, 1990, for Dr. Strom's 1990 third quarter Federal
payroll tax deposit, and he paid $7,000 on December 31,
1990, to the Employment Development Department for
Dr. Strom's California employment tax liability.
Petitioner claims to have reported receipts in 1990
from Dr. Strom in the aggregate amount of $28,560.
Petitioner testified that "Dr. Strom paid me in two checks
that year". According to petitioner, the second check in
the amount of $26,700 or $26,200 was paid on December 19,
1990. Petitioner testified:
I actually wrote out the name to Gary Friedmann,
wrote the word fee, wrote the amount and wrote
out the check. Dr. Strom signed the check and
gave it to me and it's his handwriting in there
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