- 11 - Instead of attempting to substantiate the disallowed deductions through third-party or duplicate records (e.g., statements from banks, credit card companies, local property tax records, etc.), petitioner produced various documents that he claims remained in his possession after the search. These documents include an unsigned blank check and deposit slip from a “business account”, illegible copies of credit card receipts, automobile repair bills, several bank statements for a joint checking account, a notice advising petitioner and his spouse that their automobile insurance had expired and another notice indicating that the insurance had been reinstated, a notice that petitioner’s real estate taxes for 1991 and 1992 were delinquent, a bill for a newspaper classified advertisement, a deed, a copy of a check made payable to Fleet Funding Assumption Department which appears not to have been negotiated, copies of mortgage statements, and copies of utility bills. When describing these documents at trial, petitioner acknowledged that some of them had nothing to do with deductions claimed on his 1988 return. Only some of the documents introduced into evidence by petitioner relate to 1988. According to petitioner, these documents were not seized along with his other records for that year because the agents conducting the search “missed” them. Furthermore, to the extent a document seems to relate to a deduction claimed by petitioner, it is equally plausible that the document relates toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011