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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’s
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