- 101 - Petitioner maintains that checks he gave respondent’s counsel during trial preparation compared with cash disbursement spreadsheets included in certain workpapers in evidence show that the rent payments did not go to him but instead went to third- party commercial rental agents that rented space to branch offices of IL NA Tours. Respondent contends that petitioner has not shown that IL NA Tours and Air America did not pay him rent during 1988. Respondent asserts that the evidence on which petitioner relies is not relevant to the issue of rental payments made by IL NA Tours and Air America to him because none of the checks or cash disbursement recordations relate to payments for space used by IL NA Tours or Air America. Respondent asserts further that the checks petitioner submitted do not add up to the $53,552 in total that Air America and IL NA Tours deducted as rental expense on their corporate returns. Respondent contends that petitioner’s pattern of taking money from his corporations belies his claim that he passed up an opportunity to take rental income from his corporations, especially when his activities were being carefully monitored by Northwest. We are persuaded on the basis of the record that petitioner was in error when he informed the revenue agent and respondent’sPage: Previous 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 Next
Last modified: May 25, 2011