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of $7,511, rental loss of $663, and taxable income of zero. The
tax return that petitioner filed for 1989 reflects a Schedule C
loss of $8,202, rental loss of $3,632, and taxable income of
zero. The tax return that petitioner filed for 1990 reflects a
Schedule C loss of $15,881, rental income of $2,121, and taxable
income of zero. The tax return that petitioner filed for 1991
reflects a Schedule C loss of $3,794, rental income of $4,360,
and taxable income of zero.
Contrary to the income that petitioner reported on the tax
returns that he filed for the years in issue, petitioner
submitted financial statements and tax returns to various
financial institutions in support of loan applications reflecting
substantial taxable income. On or about August 27, 1988,
petitioner submitted to Equibank a financial statement in support
of his application for a loan listing assets of $249,600,
liabilities of $700, net worth of $248,900, and gross income of
$38,150. On or about March 13, 1989, petitioner submitted to
Equibank a financial statement in support of his application for
a loan listing assets of $249,600, liabilities of $1,000, and net
income of $87,542. On or about May 3, 1991, petitioner submitted
to Colonial National Bank an application for a MasterCard credit
card listing his income as $140,000.
When petitioner applied for loans at Equibank and Commercial
Credit Corp., he submitted signed copies of Federal income tax
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