- 29 - years 1995 and 1996 and (2) the addition to tax under section 6651(a)(1) for the taxable year 1996. We turn first to the alleged unreported income. The unreported income items at issue for 1995 pertain to petitioner’s use of the January 31, 1995 check and the July 31, 1995 check, both of which were payable to Mr. Thompson, peti- tioner’s father, and issued by Polaris with respect to Mr. Thompson’s investment. The unreported income items at issue for 1996 pertain to: (1) Petitioner’s use of Weavewood’s February 1996 checks that were payable to Ms. Thompson and drawn on Weavewood’s checking account; (2) petitioner’s use of Weavewood’s February and April 1996 checks that were payable to Mr. Cavness or Mr. Villaume and drawn on Weavewood’s checking account; (3) petitioner’s use of Weavewood’s July 12, 1996 checks that were payable to petitioner and drawn on Weavewood’s checking account; (4) petitioner’s use of Weavewood’s March and April 1996 checks that were payable to Mr. Robinson and drawn on Weavewood’s checking account; (5) petitioner’s use of Weavewood’s May and June 1996 checks that were payable to Gold Key and drawn on Weavewood’s checking account; (6) petitioner’s use of the July 16, 1996 checks and the July 22, 1996 checks that were payable to Weavewood; (7) petitioner’s receipt of the February 14, 1996 check relating to Timmerman Leasing; (8) petitioner’s use of the January 31, 1996 check and the July 31, 1996 check, both of whichPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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