Kyl Christians - Page 8

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          to the loan officer’s questions, petitioner estimated that his              
          monthly income was $5,217.  Petitioner signed and dated the loan            
          application.  In mid-March 1995, petitioner entered into a                  
          contract to purchase a home for $140,000.                                   
               The mortgage company requested petitioner’s income tax                 
          returns from the previous 2 years.  Petitioner telephoned his               
          father and requested copies of his income tax returns for taxable           
          years 1993 and 1994.  Petitioner obtained copies of his income              
          tax returns from his father and submitted them to the mortgage              
          company without reviewing them.  The 1993 return submitted to the           
          mortgage company reflected Schedule C net income of $51,297.                
          This return differed in the amount of income from the one filed             
          with the Internal Revenue Service.  There were also differences             
          in petitioner’s signatures.  The date reflected on the return               
          provided to the mortgage company was April 15, 1994, and was not            
          in petitioner’s handwriting.                                                
               The 1994 income tax return submitted to the mortgage company           
          reflected Schedule C net income of $50,685, an amount different             
          from that reported to respondent.  These returns also contained             
          differences in petitioner’s signatures.  The date reflected on              
          the 1994 return provided to the mortgage company was February 2,            
          1995, and was in petitioner’s handwriting.                                  
               Petitioner did not read any of the loan documents relating             
          to the purchase of the home.  Instead, the loan officer explained           






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