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Petitioner failed to provide any documentation proving that these
deposits were from nontaxable sources.
During 1993 and 1994, petitioner also worked for Mr. Ragnar
Sundstrom preparing tax returns. Mr. Sundstrom filed Forms 1099-
MISC for payments he made to petitioner for services rendered.
During 1993, petitioner received two additional checks from
Mr. Sundstrom totaling $7,772.03: Check No. 4307 for $3,000 and
check No. 4315 for $4,772.03 (the Sundstrom payments). The
notation on check No. 4307 states "friendship". The notation on
check No. 4315 states "Bal of friendship payment".
Petitioner contends the Sundstrom payments were loans, but
he never gave respondent any evidence or documentation to support
his claim. Further, petitioner did not take any action to
produce Mr. Sundstrom to testify about the nature of the
payments.
C. Petitioners' Deductions and Credits
Petitioners claimed itemized deductions as follows:
1993 1994 1995
Real estate taxes $1,715 $1,687 $1,734
Home mortgage interest 5,237 4,866 4,337
Cash charitable contributions 190 310 215
Noncash charitable contributions -0- -0- 500
Total 7,142 6,863 6,786
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Last modified: May 25, 2011