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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 which
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